'.. . -

                     .- * .-
Environmental
Technology
Verification (ETV)
Program
Case Studies
 emonstrating
Program
Outcomes
Volume 11
*«
     United States
     Environmental Protection
     Agency

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Cover Background image from the NASA Web site at http://visibleearth.nasa.gov

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                       EPA/600/R-06/082
                        September 2006
     Environmental
Technology Verification
     (ETV) Program
      Case Studies:
     Demonstrating
  Program Outcomes
        Volume II
Recycled/Recyclable
Printed with vegetable-based ink on

§3?PCN " C°ntain8 I"1"111™"1 rf
     National Risk Management Research Laboratory
       Office of Research and Development
       U.S. Environmental Protection Agency
         Cincinnati, Ohio 45268

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                                 Notice
Development of this document was funded by the United States Environmental Protection Agency's
(EPA's) Environmental Technology Verification (ETV) Program under contract number 68-C-02-067
to Science Applications International Corporation. ETV is a public/private partnership conducted,
in large part, through competitive cooperative agreements with nonprofit research institutes. This
document has been subjected to the Agency's review and has been approved for publication as an EPA
document. Mention of trade names, products, or services does not convey, and should not be interpreted
as conveying, official EPA approval, endorsement, or recommendation. The use of company- and/or
product-specific sales information, images, quotations, or other outcomes-related information  does not
constitute the endorsement of any one verified company or product over another, nor do the comments
made by these organizations necessarily reflect the views of the U.S. EPA.
                                                Environmental Technology Verification (ETV) Program

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                             Foreword
The U. S. Environmental Protection Agency (EPA) is charged by Congress with protecting the Nation's
land, air, and water resources. Under a mandate of national environmental laws, the Agency strives to
formulate and implement actions leading to a compatible balance between human activities and the ability
of natural systems to support and nurture life. To meet this mandate, EPA's research program is providing
data and technical support for solving environmental problems today and building a science knowledge
base necessary to manage our ecological resources wisely, understand how pollutants affect our health, and
prevent or reduce environmental risks in the future.
   The National Risk Management Research Laboratory (NRMRL) is the Agency's center for
investigation of technological and management approaches for preventing and reducing risks from
pollution that threaten human health and the environment. The focus of the Laboratory's research
program is on methods and their cost-effectiveness for prevention and control of pollution to air, land,
water, and subsurface resources; protection of water quality in public water systems; remediation of
contaminated sites, sediments, and ground water; prevention and control of indoor air pollution; and
restoration of ecosystems. NRMRL collaborates with both public and private sector partners to foster
technologies that reduce the cost of compliance and to anticipate emerging problems. NRMRL's research
provides solutions to environmental problems by developing and promoting technologies that protect and
improve the environment, advancing scientific and engineering information to support regulatory and
policy decisions, and providing the technical support and information transfer to ensure implementation
of environmental regulations and strategies at the national, state, and community levels.
   This publication has been produced as  part of the Laboratory's strategic long-term research plan. It is
published and made available by EPA's Office of Research and Development to assist the user community
and to link researchers with their clients.
Sally Gutierrez, Director
National Risk Management Research Laboratory
Environmental Technology Verification (ETV) Program

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           Acknow/edgements


The ETV Program wishes to thank the verification organization partners, external peer reviewers, ETV
center project officers, EPA program office staff, and other EPA personnel who reviewed or contributed
to the case studies throughout the development process. The following individuals were instrumental in
ensuring that the information presented in the case studies was technically accurate, consistent with the
Agency's current understanding of the underlying issues, summarized fairly, and, in the case of projected
outcomes, estimated in a reasonable manner:
*  Baghouse Filtration Products: Michael Kosusko, EPA National Risk Management Research Laboratory
   (NRMRL); John Wasser, EPA NRMRL; Andrew Trenholm, RTI International; John Bosch, EPA
   Office of Air Quality Planning and Standards (OAQPS); Thomas Logan, EPA OAQPS
*  Continuous Emission Monitors (CEMs) for Mercury: Robert Fuerst, EPA National Exposure Research
   Laboratory (NERL); Thomas Kelly, Battelle; Thomas Logan, EPA OAQPS; William Maxwell, EPA
   OAQPS; Robin Segall, EPA OAQPS
*  Fuel Cells: David Kirchgessner, EPA NRMRL; Timothy Hansen, Southern Research Institute;
   Richard Adamson, Southern Research Institute; Kimberly Grossman, EPA CHP Partnership
•*•  Microturbine/Combined Heat and Power (CHP) Technologies: David Kirchgessner, EPA NRMRL;
   Timothy Hansen, Southern Research Institute; Richard Adamson, Southern Research Institute;
   Kimberly Grossman, EPA CHP Partnership; Luis Troche, EPA Office of International Affairs (OIA)
   (formerly with the CHP Partnership)
•*•  Microfiltration (MF) and Ultrafiltration (UF)for Removal of Microbiological Contaminants: Jeff Adams,
   EPA NRMRL; Bruce Bartley, NSF International; Hiba Shukairy, EPA Office of Ground Water and
   Drinking Water (OGWDW); Dan Schmelling, EPA OGWDW
*  Nanofiltratlonfor Removal of Disinfection Byproduct (DBF) Precursors: Jeff Adams, EPA NRMRL;
   Bruce Bartley, NSF International; Hiba Shukairy, EPA OGWDW; Jimmy Chen, EPA OGWDW;
   John Abraham, EPA NRMRL; Ray Smith, EPA NRMRL
*  Immunoassay Test Kits for Atrazine in Water: Robert Fuerst, EPA NERL; Amy Dindal, Battelle; Herb
   Brass, EPA OGWDW (retired); Kent Sorrell, EPA OGWDW; Patricia Fair, EPA OGWDW;
   Pritidhara Mohanty, EPA OGWDW; Diane Sherman, EPA Office of Pesticide Programs (OPP);
   Mary Frankenberry, EPA OPP; Thuy Nguyen, EPA OPP
•*•  Ultraviolet (UV) Disinfection for Secondary Wastewater Effluent and Water Reuse: Raymond Frederick,
   EPA NRMRL; Thomas Stevens, NSF International; Rodney Frederick, EPA Office of Wetlands,
   Oceans, and Watersheds (OWOW)
*  All Case Studies: Teresa Harten, EPA NRMRL; Evelyn Hartzell, EPA NRMRL; Robert Olexsey,
   EPA NRMRL; Alva Daniels, EPA NRMRL; JoAnn Lighty, University of Utah; Linda Benevides,
   Massachusetts Executive Office of Environmental Affairs; Arleen O'Donnell, Massachusetts
   Department of Environmental Protection; David Noonan, Massachusetts Department of
   Environmental Protection.
                                              Environmental Technology Verification (ETV) Program

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               Table   of  Contents
Notice                                                                                   ii
Foreword                                                                                iii
Acknowledgments                                                                       iv
Acronyms and Abbreviations                                                            vii
I.  Introduction and Summary                                                           I
    I.I    Purpose                                                                            3
    1.2    Organization and Scope                                                                7
    1.3    Summary of Outcomes                                                                9
2.  Air and Energy Technology Case Studies                                             13
    2.1    Baghouse Filtration Products                                                            15
         2.1.1      Environmental, Health, and Regulatory Background                                    16
         2.1.2      Technology Description                                                       17
         2.1.3      Outcomes                                                                 20
    2.2    Continuous Emission Monitors (CEMs) for Mercury                                           25
         2.2.1      Environmental, Health, and Regulatory Background                                    25
         2.2.2      Technology Description                                                       27
         2.2.3      Outcomes                                                                 29
    2.3    Fuel Cells                                                                          33
         2.3.1      Environmental, Health, and Regulatory Background                                    34
         2.3.2      Technology Description                                                       36
         2.3.3      Outcomes                                                                 37
    2.4    Microturbine/Combined Heat and Power (CHP) Technologies                                     41
         2.4.1      Environmental, Health, and Regulatory Background                                    42
         2.4.2      Technology Description                                                       43
         2.4.3      Outcomes                                                                 45
3.  Water Technology Case Studies                                                      49
    3.1    Microfiltration (MF) and Ultrafiltration (UF) for Removal of Microbiological Contaminants                51
         3.1.1      Environmental, Health, and Regulatory Background                                    52
         3.1.2      Technology Description                                                       53
         3.1.3      Outcomes                                                                 54
    3.2    Nanofiltration for Removal of Disinfection Byproduct (DBP) Precursors                             59
         3.2.1      Environmental, Health, and Regulatory Background                                    60
         3.2.2      Technology Description                                                       61
         3.2.3      Outcomes                                                                 62
    3.3    Immunoassay Test Kits for Atrazine in Water                                                 67
         3.3.1      Environmental, Health, and Regulatory Background                                    68
         3.3.2      Technology Description                                                       69
         3.3.3      Outcomes                                                                 71
    3.4    Ultraviolet (UV) Disinfection for Secondary Wastewater Effluent and Water Reuse                     75
         3.4.1      Environmental, Health, and Regulatory Background                                    76
         3.4.2      Technology Description                                                       78
         3.4.3      Outcomes                                                                 79
Environmental Technology Verification (ETV) Program                                                  v

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4.  References                                                                   85
Appendix A.  Methods for Baghouse Filtration Products Outcomes                  101
Appendix B.  Methods for Fuel Cell Outcomes                                     105
Appendix C.  Methods for Microturbine/Combined Heat and Power
             (CHP) Outcomes                                                  107
Appendix D.  Methods for Microfiltration (MF) and Ultrafiltration (UF) Outcomes     11 I
Appendix E.  Methods for Nanofiltration Outcomes                                115
Appendix F.  Methods for Ultraviolet (UV) Disinfection for
             Secondary Wastewater Effluent and Water Reuse Outcomes            I 19
                                              Environmental Technology Verification (ETV) Program

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                 Acronyms  and
                  Abbreviations
AA
acfm
AE
AF
AMS Center

APCT Center

ASDWA

ASERTTI
BAT
CAMR
CEM

CHP
cm w.g.
CO
C02
DBF
DBPR
DG
DOE
DWS Center

EA
EPA
atomic absorption
actual cubic feet per minute
atomic emission
atomic fluorescence
ETV's Advanced
Monitoring Systems
Center
ETV's Air Pollution
Control Technology
Center
Association of State
Drinking Water
Administrators
Association of State
Energy Research and
Technology Transfer
Institutions
best available technology
Clean Air Mercury Rule
continuous emission
monitor
combined heat and power
centimeters water gauge
carbon monoxide
carbon dioxide
disinfection byproduct
Disinfectants and
Disinfection Byproducts
Rule
distributed generation
Department of Energy
ETV's Drinking Water
Systems Center
Economic Analysis
Environmental Protection
Agency
ETV

g/dscm

GC/MS

GHG Center

HAAS

IEEE

IPCC
IRED

ISO

kW
Ibs/kWh
LT2ESWTR

MCL

MCLG

MF
MGD
mL
MW
NAAQ_S

NOAA
EPA's Environmental
Technology Verification
Program
grams per dry standard
cubic meter
gas chromatography/mass
spectrometry
ETV's Greenhouse Gas
Technology Center
the sum of five haloacetic
acids
Institute of Electrical and
Electronics Engineers
Intergovernmental Panel
on Climate Change
intelligence quotient
Interim Reregistration
Eligibility Decision
International Standards
Organization
kilowatts
pounds per kilowatt-hour
Long Term 2 Enhanced
Surface Water Treatment
Rule
maximum contaminant
level
maximum contaminant
level goal
microfiltration
million gallons per day
milliliters
megawatts
National Ambient Air
Quality Standards
National Oceanic
and Atmospheric
Administration
Environmental Technology Verification (ETV) Program

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NOX
OAQPS
OH
PAFC
PCI

PEM

PM
PM
   '2.5
ppb
PSWA

RIA
nitrogen oxides
EPAs Office of Air Quality
Planning and Standards
Ontario Hydro
phosphoric acid fuel cell
PCI Membrane Systems
Inc.
polymer electrolyte
membrane fuel cell
particulate matter
fine PM with a nominal
aerodynamic diameter of
10 micrometers or less
fine PM with a nominal
aerodynamic diameter of
2.5 micrometers or less
parts per billion
Pittsburgh Sewer and
Water Authority
Regulatory Impact
Analysis
SCAQMD

SIP
S02
Texas CEQ_

THCs
TMDL

TTHM
UF
UV
WQP Center

Hg/L
|_ig/m3

|_ig/scm
South Coast Air Quality
Management District
State Implementation Plan
sulfur dioxide
Texas Commission on
Environmental Quality
total hydrocarbons
Total Maximum Daily
Load
total trihalomethane
ultrafiltration
ultraviolet
ETV's Water Quality
Protection Center
micrograms per liter
micrograms per cubic
meter
micrograms per standard
cubic meter
viii
                                Environmental Technology Verification (ETV) Program

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 Introduction
and Summary

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                                                                Purpose
            This document is the second
            volume in a collection of case
            studies that document actual and
            project estimated (or potential)
            outcomes and benefits of the
U.S. Environmental Protection Agency's (EPA's)
Environmental Technology Verification (ETV)
Program. The first volume (U.S. EPA, 2006f) was
published in January 2006 and can be found at http://
www. epa.gov/etv/sitedocs/program-index. html.
    The ETV Program was initiated in 1995 to
verify the performance of innovative technologies
that have the potential to improve human health
and the environment. The  program operates, in
large part, as a public-private partnership through
competitive cooperative  agreements between EPA
and the five nonprofit research institutes listed
in Exhibit 1.1-1, although some verifications are
performed under contracts. The  ETV Program,
through its cooperative agreement recipients,
develops testing protocols and publishes detailed
performance results in the  form  of verification
reports and statements, which can be found at
http://www.epa.gov/etv/verificatiom/verification-
index.html. EPA technical  and quality assurance
staff review the protocols, test plans, verification
reports, and verification  statements to ensure that
the verification data have been collected, analyzed,
and presented in a manner that is consistent with
EPA's quality assurance guidelines. By providing
credible performance information about new and
improved, commercially ready environmental
technologies, ETV verification can help vendors
sell their technologies and  help users make
purchasing decisions. Ultimately, the environment
and public health benefit.
   The Government Performance and Results
Act (GPRA) of 1993 holds federal agencies
accountable for using resources wisely and
achieving program results. Among other things,
GPRA requires agencies to measure their
performance and communicate this information
to Congress and to the public. In measuring
performance, GPRA distinguishes between
"output" measures and "outcome" measures.
Output measures assess a program's activities in
their simplest form, such as counting the number
of projects completed. Outcome measures assess
the results of these activities compared to their
intended purpose, for example, by quantifying the
benefits of those projects (GPRA, 1993).
   Historically, the ETV Program has
measured its performance in terms of outputs,
for example, the number of technologies
verified and testing protocols developed. ETV
is expanding its approach to include outcomes,
such as pollution reductions attributable to
the use of ETV technologies and subsequent
health or environmental impacts. These case
studies highlight how the program's outputs
have translated into actual outcomes and predict
potential outcomes based on market penetration
scenarios. The program also will use the case
studies to communicate information about verified
technology performance, applicability, and ETV
testing requirements to the public and decision-
makers.
Environmental Technology Verification (ETV) Program

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/. INTRODUCTION AND SUMMARY
   In reviewing these case studies, the reader
should keep in mind the following:

*  Given the current state of science, there can
   be considerable uncertainty in predicting
   environmental outcomes and human health
   benefits. Therefore, many of the outcomes
   quantified in these case studies are potential
   outcomes, and should be treated as estimates
   only. Also, in general, these estimates were
   calculated by assuming a straight-line
   relationship between pollutant reductions
   and reductions in health effects estimated
   in publicly available resources, for example,
   regulatory impact analyses. In most cases, this
   estimation method is likely a simplification
   of the actual relationship between pollutant
   reductions and health effects. It also probably
   simplifies the relationship between pollutant
   reductions and ambient concentrations, and the
   relationship between ambient concentrations
   and health effects. In general, these estimates
   also do not account for localized impacts, which
   are likely to  be observed under lower market
   penetration  scenarios.
*  Vendors of ETV-verified technologies are
   not required to track their sales or report the
   effects of ETV verification to EPA. Therefore,
   the ETV Program does not have access to a
   comprehensive set of sales data for the verified
   technologies. Faced with this limitation,
   ETV has estimated outcomes using "market
   penetration scenarios."That is, ETV has
   estimated the potential market for a given
   technology or technology group and applied
   scenarios, for example, 10% and 25% of this
   market, to project the number of applications
   for the technology category. Where sales
   information is available, however, ETV has
   incorporated this information into its market
   penetration scenarios (see, for example, the
   case study in Section 2.4).
*  The outcomes presented here were not
   produced during the verification tests
   themselves.  Instead, the ETV Program has
   calculated these outcomes by combining the
   verified performance results (which can be
   found at http://www.epa.gov/etv/verificatiom/
   verification-indexMml) with data from
   publicly available sources such as regulatory
impact analyses, reasonable assumptions, and
logical extrapolations.
These case studies are not intended as a basis
for making regulatory decisions, developing
or commenting on policy, or choosing to
purchase or sell a technology. They are
merely intended to highlight benefits or
other outcomes that could be attributed to
verification and verified technology use.
The ETV Program does  not compare
technologies. Therefore, when  a case
study discusses a group of similar verified
technologies, it summarizes performance
results in the form of a range or without
identifying the specific vendor associated with
a given result. When results are listed in a
tabular format, the vendor and product names
are not mentioned and the results are listed in
a random order.  Specific results for all verified
technologies can be found at http://www.epa.
gov/etv/verifications/verification-index.html.
Verified technology performance data and
other information found in the verification
reports were used, in part, to develop the case
studies. The cooperative agreement recipients
make the final decisions on the content of the
verification reports, which are considered the
products of the ETV cooperative agreement
recipients. EPA technical and quality
assurance staff review the protocols, test plans,
verification reports, and verification statements
to ensure that the verification data have been
collected, analyzed, and presented in a manner
that is consistent with EPA's quality assurance
guidelines.
Verification organization partners, the ETV
center EPA project officers, and appropriate
program office and other EPA personnel
have reviewed the case studies  throughout
the development process. These reviews were
performed to ensure that the information
presented in the case studies was technically
accurate, consistent with the Agency's
current understanding of the underlying
issues, summarized fairly, and,  in the case
of outcomes, estimated in a reasonable
manner. Vendors were also provided with an
opportunity to review the pre-final versions of
the case studies.
                                                      Environmental Technology Verification (ETV) Program

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                                                                                    /. INTRODUCTION AND SUMMARY
   Three of the eight case studies presented here
   were initially based on draft case studies (U.S.
   EPA, 2002a; NSF, 2004; Battelle, 2004a) that
   were developed by EPA ETV Program staff
   and verification partners. These case studies
   include text and other information found in
   the draft documents.
                         EPA does not endorse the purchase or sale
                         of any of the products and services from
                         companies mentioned in this document.
                         Also, the use of company- and/or product-
                         specific sales information, images, quotations,
                         or other information does not constitute the
                         endorsement of any one verified company or
                         product over another, nor do the comments
                         made by these organizations necessarily reflect
                         the views of the U.S. EPA.
                             ETV CENTERS AND VERIFICATION ORGANIZATIONS
      ETV Center/Pilot

      ETV Advanced Monitoring
      Systems (AMS) Center
      ETV Air Pollution Control
      Technology (APCT) Center
      ETV Drinking Water Systems
      (DWS) Center

      ETV Greenhouse Gas Technology
      (GHG) Center
      ETVWater Quality Protection
      (WQP) Center

      ETV Pollution Prevention (P2)
      Coatings and Coating Equipment
      Pilot (CCEP)
 Verification Organization
Battelle
RTI International
           Technology Areas and
      Environmental MediaAddressed
* Air, water, and soil monitoring
* Biological and chemical agent detection in water

* Air pollution control
NSF International
Southern Research Institute
NSF International
Concurrent Technologies
Corporation (CTC)
* Drinking water treatment
* Biological and chemical agent treatment in water

* Greenhouse gas mitigation and monitoring

* Storm and waste water control and treatment
* Biological and chemical agent wastewater treatment

* Pollution prevention for coatings
Environmental Technology Verification (ETV) Program

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                                                                            1.2
      Organization   and  Scope
           This document includes case studies
           of eight selected ETV-verified
           technologies or technology groups.
           Section 2 presents four "Air and
           Energy Technology" case studies.
           Section 3 presents four "Water
Technology" case studies. One of the case studies
is an update of a case study originally published
in the first volume of this document (U.S. EPA,
2006f). Section 4 is a complete list of references
and the document concludes with a set of
appendices that provide a detailed discussion of
the methods used to estimate outcomes in several
of the case studies.
   Exhibit 1.2-1 lists the eight case studies,
shows the ETV center that verified each, and
identifies the priority environmental topics and
significant pollutants addressed by each.
   Each case study begins with a summary
of actual and estimated outcomes, followed by
three sections. The first section, "Environmental,
Health, and Regulatory Background," describes:
(1) the pollutant or environmental issue the
technology is designed to address, (2)  the human
health and environmental impacts associated
with the pollutant or issue, and (3) regulatory
programs or voluntary initiatives under which
the technology can be applied. The second
section, "Technology Description," describes the
technology, identifies what makes the  technology
innovative, and summarizes the performance
results as verified by ETV. The third section,
"Outcomes," presents, in detail, the ETV
Program's estimates of outcomes from verification
and from implementing the technology. These
outcomes include:

*  Pollutant (or emissions) reduction outcomes,
   such as pounds of pollutant removed
   nationwide by actual or projected applications
   of the technology
*  Environmental and human health outcomes,
   such as cases of disease or death avoided,
   nationwide, by actual or projected applications
   of the technology
*  Resource conservation outcomes, such as the
   types of natural or man-made resources that
   the technology can conserve
*  Economic and financial outcomes, such as the
   economic value of avoided cases of disease or
   cost savings to users  of the technology
*  Regulatory compliance outcomes, such as the
   number of facilities that the technology can
   assist in complying with a regulation
*  Technology acceptance and use outcomes,
   such as evidence that ETV verification has led
   to increased use of the technology
*  Scientific advancement outcomes, such as
   improvements in technology performance due
   to ETV verification  or scientific uncertainties
   that can be addressed by verification.
   Within each outcome category, the ETV
Program made every effort to quantify, that is,
place a numerical value on, the outcome. Where
Environmental Technology Verification (ETV) Program

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/. INTRODUCTION AND SUMMARY
             CASE STUDIES, PRIORITY ENVIRONMENTAL TOPICS, AND SIGNIFICANT POLLUTANTS
      Case Study and Section
      Number
     2.1 Baghouse Filtration Products
     2.2 Continuous Emission Monitors
     (CEMs) for Mercury
     2.3 Microturbine/Combined Heat
     and Power (CHP) Technologies

     2.4 Microturbine/Combined Heat
     and Power (CHP) Technologies (2)
   ETV
Center (I)    Priority Environmental Topics
       Air and  Energy Technologies
      T     Industrial emissions, children's health
      5      Industrial emissions, children's health
   GHG
   GHG
                                           Greenhouse gases, waste-to-energy,
                                           community development

                                           Greenhouse gases, waste-to-energy,
                                           community development
   Significant Pollutants

  ^^•^^H
Fine particulate matter (PM2.5)
Mercury

Carbon dioxide, nitrogen
oxides, carbon monoxide, total
hydrocarbons
Carbon dioxide, nitrogen oxides,
sulfur dioxide, methane, carbon
monoxide, particulate matter,
ammonia, total hydrocarbons
                                               Water Technologies
                                                 Small drinking water systems
                                                 Small drinking water systems
                                                 Drinking water compliance, watershed
                                                 protection
                                                 Watershed protection, community
                                                 development
                                               Cryptosporidium and
                                               Gyf>tosf>orid/um-sized particles

                                               Trihalomethanes and haloacetic
                                               acids

                                               Atrazine
3.1 Microfiltration (MF) and            DWS
Ultrafiltration (UF) for Removal of
 licrobiological Contaminants
3.2 Nanofiltration for Removal          DWS
of Disinfection Byproduct (DBP)
Precursors
3.3 ImmunoassayTest Kits for           AMS
Atrazine in Water
3.4 Ultraviolet (UV) Disinfection       WQP
for Secondary Wastewater Effluent
and Water Reuse
(I) APCT = Air Pollution Control Technology Center; GHG = Greenhouse Gas Technology Center; CCEP = Coatings and Coating
Equipment Pilot; AMS = Advanced Monitoring Systems Center; DWS = Drinking Water Systems Center;
WQP = Water Quality Protection Center

(2) Updated from the case study originally presented in the first volume of this document (U.S. EPA, 2006f)
                                               Pathogenic organisms, such as
                                               E. coli and enterococci
insufficient data were available to quantify an
outcome, the case studies present information
about that outcome and describe its projected
significance qualitatively.
    Each case study is written to stand on its own,
so that readers interested in only one technology
category (or a few categories) can direct their
attention to the section(s) of interest without
needing to review the entire document. For this
                      reason, each case study spells out acronyms (other
                      than EPA and ETV) on first use within that case
                      study, even if those acronyms have been used in
                      previous case studies. To further aid readers, each
                      case study also includes its own acronyms list at
                      the end of the section. For readers who wish to
                      review all the case studies together, a complete
                      acronyms list is included at the beginning of this
                      document.
                                                             Environmental Technology Verification (ETV) Program

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         Summary  of Outcomes
           The case studies presented here
           address a variety of pollutants and
           environmental issues (see Exhibit
           1.2-1). As discussed above, the
           ETV Program examined a number
of types of outcomes and attempted, within
the limits of the available data, to quantify
each outcome. This section identifies the types
                                         of outcomes associated with each case study
                                         and provides examples of the most significant
                                         quantifiable actual and projected outcomes.
                                         Exhibit 1.3-1 lists the eight case studies, with
                                         the types of outcomes identified in each. It
                                         also indicates which of the outcomes the ETV
                                         Program was able to quantify.
    Case Study and Section Number
                                  Air and Energy Technologies

                                            Q
2.1 Baghouse Filtration Products
2.2 Continuous Emission Monitors (CEMs) for Mercury
2.3 Fuel Cells
2.4 Microturbine/Combined Heat and Power (CHP)
Technologies (2)
                                 Water Technologies
3.1 Microfiltration (MF) and Ultrafiltration (UF) for Removal          Q
of Microbiological Contaminants
3.2 Nanofiltration for Removal of Disinfection Byproduct
(DBP) Precursors
3.3 ImmunoassayTest Kits forAtrazine in Water
                                                                            X
    3.4 Ultraviolet (UV) Disinfection for Secondary Wastewater
    Effluent and Water Reuse
/astewater
X
X
Q
Q
X
X
Q
X
X
X
X
    Blank = ETV did not identify this type of outcome                  •	
    X = ETV identified this type of outcome, but was not able to quantify its potential impact
    Q = ETV identified this type of outcome and was able to quantify its potential impact
    (I) ETV estimates that information provided by the monitors ultimately can assist in reduction of emissions or pollutant releases,
    with environmental and human health benefits
    (2) Revised from the case study originally presented in the first volume of this document (U.S. EPA, 2006f)
Environmental Technology Verification (ETV) Program

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/. INTRODUCTION AND SUMMARY
    Examples of some of the significant outcomes
from those identified in Exhibit 1.3-1 include the
following:

*   The ETV-verified baghouse filtration
    products would result in human health and
    environmental benefits, including up to 68
    avoided cases of premature mortality per year,
    with an economic value of up to $450 million
    per year,1 assuming 25% market penetration.
    California has adopted a rule (Rule 1156) that
    provides incentives for cement manufacturing
    facilities to use the ETV-verified baghouse
    fabrics to control particulate emissions. EPA's
    Office of Air Quality Planning and Standards
    (OAC^PS) is preparing a memorandum
    to encourage EPA regional offices and
    other agencies to consider adopting similar
    regulations.
*   ETV verification of mercury continuous
    emissions monitors (CEMs) has helped
    inform the development to the Clean Air
    Mercury Rule (CAMR) and resulted in
    improvements in monitors by the participating
    vendors. The verified monitors, or monitors
    improved as a result of testing, could be
    applied at approximately 340 utilities that
    EPA estimates would use CEMs to meet
    monitoring requirements under the CAMR.
    The information provided by the verified
    monitors will ultimately assist in achieving
    mercury emissions reductions, with associated
    human health, environmental, and economic
    benefits.
*   The ETV-verified fuel cells would reduce
    carbon dioxide (CO2) emissions by 41,000
    tons per year and nitrogen oxide (NOX)
    emissions by 270 tons per year, with associated
    climate change and environmental and
    human health benefits, assuming annual sales
    continue at the same rate as in 2005 over the
    next five years. Many of the fuel cells would
utilize renewable fuels, such as anaerobic
digester gas, resulting in reductions in the
consumption of natural resources.
The ETV-verified microturbine/combined
heat and power (CHP) technologies would
reduce CO2 emissions by up to 150,000 tons
per year and NOX emissions by up to 530
tons per year, with associated climate change
and environmental and human health benefits,
assuming annual sales continue at the same
rate as in 2005 over the next five years.
The ETV-verified microfiltration (MF)
and ultrafiltration (UF) technologies would
prevent up to 13,000 cases of cryptosporidiosis
per year and up to two premature deaths
per year associated with these cases, with an
associated economic value of up to $19 million
per year,2  assuming 25% market penetration.
States such as Utah and Massachusetts
are willing to use ETV verification data to
approve technology use at the state level.
The ETV-verified nanofiltration technology
could prevent up to 20 cases of bladder cancer
per year, with an associated economic value
of up to $110 million per year,3 assuming
25% market penetration.4 States such as Utah
and Massachusetts are willing to use ETV
verification data to approve technology use at
the state level.
The ETV-verified immunoassay test kits for
atrazine in water would result in national
sampling-cost savings of up to $5,000,000 per
year,5 assuming the test kits  partially replace
conventional methods in model sampling
programs at up to 960  community surface
water systems and up to 2,500 watersheds
(representing 25% market penetration). ETV
data will contribute to  EPA's future decision
to modify or withdraw one of the approved
analysis methods used for drinking water
compliance.
1 In 1990 dollars.
2 In year 2003 dollars.
3 In year 2003 dollars.
4 In 71 FR 388, EPA acknowledges that causality has not yet been established between chlorinated water and bladder cancer and that the
  actual number of cases attributable to disinfection byproducts could be zero. Therefore, the actual number of cases avoided and associated
  economic value could be as low as zero.
5 In late 1990s dollars.
10
Environmental Technology Verification (ETV) Program

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                                                                                /. INTRODUCTION AND SUMMARY
   The ETV-verified UV disinfection
   technologies would result in the capacity to
   recycle up to 140 million gallons of water
   per day, with associated human health,
   environmental, and economic benefits,
   assuming 25% market penetration in Florida
   and California alone.
Environmental Technology Verification (ETV) Program                                                     11

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         Air and Energy
Technology Case Studies

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                                                                           2.1
                                                     Baghouse
                         Filtration   Products
           The ETV Air Pollution Control
           Technology (APCT) Center,
           operated by RTI International (RTI)
           under a cooperative agreement with
           EPA's National Risk Management
Research Laboratory, has verified the performance
of 16 technologies for reducing emissions of fine
particulate matter (PM2 s), and has an additional
verification in progress. These technologies use
fabric filters to remove particulate matter (PM)
from stationary emission sources. Fabric filters,
or baghouses, are widely used for controlling
PM from a variety of industrial sources such as
utility and industrial boilers, metals and mineral
processing facilities, and grain milling (U.S. EPA,
2003d, 2003k, 20031). ETS, RTFs subcontractor
during the verifications, estimates that there are
more than 100,000 baghouses in the United
States, of which 10,000 are medium to large
(McKenna, 2006).6 PM2 s contributes to serious
public health problems in the U.S., including
premature mortality and respiratory problems,
and has other environmental impacts, including
reduced visibility. To help address the public
health effects of PM2S, EPA has  established
National Ambient Air Quality Standards
(NAAQ_S) for PMZS. In April 2005, EPA
identified that there were 39 areas of the country
that exceed the current NAAQS  for PM2 s. These
areas are required to meet the NAAQS for PM2 s
by no later than April 2010, although EPA can
grant extensions to this date of up to five years in
certain cases. States are required to prepare State
Implementation Plans (SIPs) by April 2008 to
describe how these areas will meet the standards
(U.S. EPA, 2006b; 70 FR 65984).
   Verification has increased awareness of
technologies that could be used to reduce PM2 s at
the state, local, and user level, with the following
benefits:

*  California has adopted a rule (Rule 1156) that
   provides incentives for cement manufacturing
   facilities to use the ETV-verified baghouse
   fabrics to control particulate emissions. By
   reducing the required compliance testing
   frequency from annually to every five years,
   this rule can provide a significant cost savings
   to users of the verified technologies. EPA's
   Office of Air Quality Planning and Standards
   (OAQPS) is preparing a memorandum to
   encourage EPA regional offices and other
   agencies to use the ETV protocol and to
   consider adopting similar regulations.
*  ASTM International has adopted the
   ETV baghouse filtration testing protocol
   as its standard, promoting standardization
   and consistency in performance evaluation
   for these technologies. The International
   Standards Organization (ISO), a worldwide
   voluntary standards organization, has also
   proposed the ETV testing protocol as their
6 For purposes of these statistics, ETS considers baghouses of 50,000 to 250,000 acfm to be medium and those above 250,000 acfm to be
  large.

Environmental Technology Verification (ETV) Program                                             15

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
    standard. It is progressing through the ISO
    adoption and approval process.
*  Industry sources suggest that verification data
    can assist facilities in selecting technologies
    and state and local agencies in evaluating
    permit applications.  One vendor reports that
    ETV verification facilitated the permitting
    process for at least one customer and other
    vendors report that ETV data have helped
    them compete in the marketplace. Vendors
    also have continued to participate in additional
    rounds of testing to maintain their verified
    status and verify new products.
    Based on the analysis in this case study and
25% market penetration, the ETV Program also
estimates that:

*  Ninety large facilities (out of 358 large
    facilities)7 would apply the ETV-verified
    baghouse filtration products, reducing PM2 s
    emissions by a total 7,600 tons per year. This
    estimate only counts large facilities in 39 areas
    of the country that exceed the NAAQS for
    PM2S. The total number of facilities with
    the potential to apply the technologies, and
    the associated pollutant reductions, would be
    much greater.8
*  The PM2.S reductions at 90 facilities would
    result in human health and environmental
    benefits, including up to 68 avoided cases of
    premature mortality per year, with an economic
    value of up to $450 million per year.9
   2.1.1  Environmental, Health, and
   Regulatory Background
PM is a generic term for a variety of solids
or liquid droplets over a wide range of sizes.
Two mechanisms account for the presence of
atmospheric PM: primary emission and secondary
formation. Primary particles are emitted directly
into the air as a solid or liquid particle. Secondary
particles form in the atmosphere as a result of
chemical reactions among precursors such as
sulfate, ammonia, and nitrate species. Airborne
PM with a nominal aerodynamic diameter of
2.5 micrometers is considered to be fine PM or
PM2.S (70 FR 65984). Both primary emission and
secondary formation are significant contributors
to atmospheric PM2 s.
    In 2002, U.S. sources emitted an estimated
6.8 million short tons of PM2S. Most of
these emissions originated from uncontrolled,
fugitive sources such as agriculture, wildfires,
and dust.  Stationary point sources, however,
also contributed a significant portion of total
PM2 s emissions. These stationary point
sources include stationary non-residential fuel
combustion (approximately 900,000 short tons
of PM2 s), mineral products (approximately
200,000 short tons), and other industrial
processes  (approximately 200,000 short tons)
(U.S. EPA, 2005g). The ETV-verified baghouse
technologies can be used for the control of
emissions from many of these stationary point
sources. Based on data from U.S. EPA (2003d,
2003k, and 20031), the following industry
categories are  amenable to baghouse technology
for PM2S  control:
*  Combustion of coal  and wood in electric
    utility, industrial, and commercial/institutional
    facilities

*  Ferrous and non-ferrous metals processing

*  Asphalt manufacturing

*  Grain milling

*  Mineral products.
    These industry categories account for 13% of
national PM2 s emissions (see Appendix A).
    Atmospheric PM results in detrimental
human health  and environmental effects. Health
effects associated with exposure to elevated PM2 s
levels include the following: premature mortality,
aggravation of respiratory and cardiovascular
disease, lung disease, decreased lung function,
asthma attacks, and cardiovascular problems. The
elderly, people with heart and lung disease, and
children are particularly sensitive to PM2 s (70
7 Large facilities are those that emit more than 100 tons per year of PM2.s.
8 ETV used this conservative estimate of the number of facilities because it includes the facilities most likely to require increased control
  under the NAAQ_S for PM2.5.
9 In 1990 dollars.
16
   Environmental Technology Verification (ETV) Program

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                                                                    2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
FR 65984). PM2 s results in visibility impairment
associated with regional haze by scattering or
absorbing light. Hazardous trace metals such
as arsenic, cadmium, nickel, selenium, and zinc
from combustion processes tend to concentrate
preferentially in the fine PM fractions in primary
emission sources. Reductions in PM2 s can have the
added benefit of reducing emissions of hazardous
metals (70 FR 65984; Mycock et al., 2002).
    EPA is responsible under the Clean Air Act
for  setting NAAQS for pollutants considered
harmful to public health and the environment.
EPA established the first NAAQS for PM in
1971 and has revised these standards as new
scientific information became available. Initially,
EPA issued standards for "total suspended
particulate." In 1987, the NAAQS were revised to
address PM with a nominal aerodynamic diameter
of 10 micrometers (PM10) or less to protect
against human health effects from deposition of
these smaller particles in the lower respiratory
tract. EPA later established NAAQS for PM2 s in
1997 and presently has standards for both PM10
and PM2.S (U.S. EPA, 2004b). These standards
include an annual average of 15 micrograms per
cubic meter (u.g/m3) and a 24-hour standard of
65 u.g/m3. Finally, in January 2006, to further
improve public health across the country, EPA
proposed to  revise the NAAQS for PM2.S. The
proposed rule would lower the 24-hour standard
to 35 u.g/m3,10 while retaining the annual standard
at its current level. The proposal also solicits
comment on alternative levels for the standards
(71 FR 2620).
    In April 2005, EPA identified 39 areas of
the country, with a population of 90 million
(representing about 30% of the U.S. population),
that exceed the current NAAQS for PM2 s. These
areas are known as "non-attainment" areas. These
areas are required to meet the NAAQS for PM2 s
by no later than April 2010, although EPA  can
grant extensions to this date of up to five years in
certain cases. States are required to prepare  State
Implementation Plans (SIPs) by April 2008 to
describe how these areas will meet the standards
(U.S. EPA, 2006b; 70 FR 65984). In November
2005, EPA issued a proposed rule identifying the
          aghouses and their accompanying filter
          media have long been one of the leading
  particulate control technologies for industrial
  sources. Increasing emphasis on higher removal
  efficiencies has helped the baghouse to be
  continually more competitive when compared to
  the other generic PM control devices to the point
  where it is now the control option of choice for
  most industrial applications.The development of
  new and improved filter media has further enhanced
  baghouse capability to control fine PM over an
  expanded range of industrial applications."
  —ETS and RTI, 2001 e
 ,.	
requirements that states must meet in preparing
these SIPs (70 FR 65984).
  2.1.2  Technology Description
Fabric filter, or baghouse, technology has long
been used for controlling particulate emissions
from industrial stationary sources. Baghouses
are capable of reducing emissions of various
particulate sizes (e.g., total PM, PM10, PM2 s),
as well as hazardous air pollutants present in
particulate form. There are two principal types of
baghouses, pulse jet and reverse air. In a typical
pulse jet baghouse application, flue gas passes
through a fabric where particulate is retained as
a result  of sieving and other mechanisms. Fabric
is typically in the shape of a cylindrical bag, with
gas flowing from the outside to the inside prior
to being emitted to the atmosphere. As particles
build up, the differential pressure (pressure drop)
increases. Periodically, the particulate material is
removed from the filter using techniques such as
rapid pulse cleaning, where a pulse of compressed
air is forced through the filter from the clean gas
side to dislodge the dust (U.S. EPA, 2003d).  A
reverse air baghouse is similar except  gas flows
from the inside to the outside of the bag and the
direction of airflow is reversed to clean the bags
(U.S. EPA, 2003k).
   The ETV Program has verified the
performance of 16 baghouse filtration products
designed primarily to reduce PM2 s emissions,
10 The annual standard is based on the three-year average of annual mean PMj.5 concentrations. The 24-hour standard is based on the
  three-year average of the 98th percentile of 24-hour PMis concentrations.

Environmental Technology Verification (ETV) Program                                                     17

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
Installing a fabric swatch in the test apparatus

and has an additional verification in progress. All
of the verified products are commercial fabrics
used in baghouse emission control devices. The
                verification reports (ETS and RTI, 2000a, 2000b,
                2000c, 2000d, 2000e, 2000f, 2000g, 2000h, 2000i,
                2001a, 2001b, 2001c, 2001d, 2002,2005,2006) can
                be found at http://www.epa.gov/etv/verifications/
                vcenter5-2.html. Due to the evolving nature of these
                products and their markets, the baghouse filtration
                products verification statements are valid for three
                years from the date of verification. Exhibit 2.1-1
                identifies the verified technologies.
                    During verification testing, each baghouse
                filtration product underwent the following:

                *  A conditioning period of 10,000 rapid pulse
                    cleaning cycles
                *  A recovery period of 30 normal filtration
                    cycles
                *  A six-hour performance test period.
                    During all three periods, the products
                were subjected to a continuous and constant
                               ETV-VERIFIED BAGHOUSE FILTRATION PRODUCTS
      Technology Name
      Air Purator Corporation, Huyglas® I405M
 Verification Date
 September 2000

 September 2000

 September 2000

 September 2000


 September 2001

^^^^^H
 June 2002

 September 2005
^^^^^l^^^^^^^^^l
 September 2000
 September 2000
 September 2001
 September 2000

 September 2000

 September 2001

 September 2000

 September 2001
 July 2006
      Albany International Corporation,
      Primatex™ Plus I
      BASF Corporation,AX/BA-l4/9-SAXP®
      I405M
      BHA Group, lnc.QG06l®
      BHAGroup,lnc.QPI3l*


      BWF America, Inc. Grade 700 MPS
      Polyester8
      BWF America, Inc. Grade 700 MPS
      Polyester® Felt
      Inspec Fibres 55I2BRF®
      Menardi-Criswell 50-504®
      Polymer Group, Inc. DURAPEX™ PET
      Standard Filter Corporation Capture®
      PEI6ZU®
      ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^H
      Tetratec PTFE Technologies Tetratex® 8005

      Tetratec PTFE Technologies Tetratex® 6212

      W.L Gore & Associates, Inc. L4347®

      W.L. Gore & Associates, Inc. L4427®
      W.L. Gore & Associates, Inc. L3560®
      Sources: ETS and RTI, 2000a, 2000b, 2000c, 2000d, 2000e, 2000f, 2000g, 2000h, 2000i, 2001 a, 2001 b, 2001 c, 2001 d, 2002,2005,2006.
                  Description

An expanded polytetrafluoroethylene film applied to a
glass felt for use in hot-gas filtration.
A polyethylene terephthalate filtration fabric with a fine
fibrous surface layer.
A Basofil filter media

A woven-glass-base fabric with an expanded, microporous
polytetrafluoroethylene membrane, thermally laminated to
the filtration/dust-cake surface
     ^^^^^H                               ^^^H
A polyester needlefelt substrate with an expanded,
microporous polytetrafluoroethylene membrane,thermally
laminated to the filtration/dust-cake surface
A micro-pore-size, high-efficiency, scrim-supported felt
fabric
A micro-pore-size, high-efficiency, scrim-supported felt
fabric
A scrim-supported needlefelt.
A singed microdenier polyester felt
A non-scrim-supported 100% polyester, non-woven fabric
A stratified microdenier polyester non-woven product

A polyester scrim-supported needlefelt with an expanded
polytetrafluoroethylene membrane
A polyester needlefelt with an expanded
polytetrafluoroethylene membrane
An expanded polytetrafluoroethylene membrane/polyester
felt laminate
A membrane/polyester felt laminate
A membrane/fiberglass fabric laminate
 18
                   Environmental Technology Verification (ETV) Program

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                                                                       2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
dust loading. The performance parameters
verified included the following: filter outlet
PM2 s concentration, filter outlet total mass
concentration, pressure drop, filtration cycle time,
and mass gain on the filter fabric.
    Exhibit 2.1-2 summarizes  some of the
performance data for the individual baghouse
filtration products. Because the ETV Program
does not compare technologies, the performance
results shown in Exhibit 2.1-2 do not identify
the vendor associated with each result and are
not in the same order as the list of technologies
in Exhibit 2.1-1. The ETV Program found that
the baghouse filtration products resulted in outlet
PM2S concentrations of less than 2xlO~6 to 38xlO~s
grams per dry standard cubic meter (g/dscm), and
total particulate concentrations of less than 2xlO~6 to
42xlO~s g/dscm. The residual pressure drop ranged
from 2.45 to 15.0 centimeters  water gauge (cm
w.g.), and residual pressure drop increase ranged
from 0.18 to 7.84 cm w.g.
                              UNDERSTANDING RESIDUAL PRESSURE DROP
                              AND RESIDUAL PRESSURE  DROP INCREASE
                                   The process of cleaning  the bags in a baghouse
                                   is cyclic and involves a  periodic pulse of
                              compressed air to remove dust collected on the bags.
                              The "residual pressure drop" is the pressure drop
                              measured across the bag fabric just after the bag
                              cleaning and is the result of the resistance to flow
                              created by the fabric and any remaining dust on the
                              fabric. After cleaning, the pressure drop across the
                              fabric increases to a predetermined value as dust is
                              removed from the dirty gas stream and collects on
                              the fabric surface.This predetermined value is the
                              "residual pressure drop increase." At this point the
                              bags are cleaned again and the cycle is completed.
                              The residual pressure drop and the amount the
                              pressure increases during a cleaning cycle are
                              important parameters for the user of the verification
                              data to understand the context of the emissions
                              performance results. (Trenholm and McKenna, 2006)
                  PERFORMANCE OF EIV-VERIFIED BAGHOUSE FILTRATION PRODUCTS
      Technology
     A
     B
     C
     D
Outlet Particle Concentration
       (g/dscm x 10-6)
 PM"
                              2
                            6.8
                            <2

                            •
                            32
                   Residual Pressure
 Total Mass          Drop,(cm w.g.)
Membrane Fabrics
    120                  8.46
                         7.38
                         4.92
        ^^^^^^^^^^^^^^^^^^^^^M
    11.5
Residual Pressure
  Drop Increase
    (cm w.g.)
                        <2
                 Non-membrane Fabrics
                        68
                                                 67.6
     Values rounded to three or fewer significant figures.
     Sources: ETS and RTI, 2000a, 2000b, 2000c, 2000d, 2000e, 2000f, 2000g, 2000H, 2000i, 2001 a, 2001 b, 2001 c, 2001 d, 2002,2005,2006.
11 Because the ETV Program does not compare technologies, the performance results shown in Exhibit 2.1-2 do not identify the vendor
  associated with each result and are not in the same order as the list of technologies in Exhibit 2.1-1.

Environmental Technology Verification (ETV) Program                                                       19

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
  2.1.3 Outcomes
ETS, RTFs subcontractor during the verifications,
estimates that there are more than 100,000
baghouses in the United States, of which 10,000
are medium to large (McKenna, 2006).12 For this
analysis, however, ETV has limited its estimate
of the market for the ETV-verified baghouse
filtration products to large stationary sources
located in areas of the country that exceed the
NAAQS for PM2 s (i.e., non-attainment areas).
Accordingly, the ETV Program used data from
a technical background document for EPA's
proposed rule outlining SIP requirements for
PM2.S (U.S. EPA, 2005h) to estimate the potential
market for the verified filtration products. This
document estimated that there were 358 facilities
that each emit more than 100 tons per year of
PM2 s located in non-attainment areas.
   As discussed below under "Technology
Acceptance and Use Outcomes," there is a robust
market for baghouse filtration products. Because
the ETV Program does not have access to a
comprehensive set of sales data for the ETV-
verified technologies, the ETV Program used
a conservative market estimate and two market
penetration scenarios, 10% and 25% of the
potential market, to estimate pollutant reduction
outcomes. Exhibit 2.1-3 lists the estimated
number of facilities that would apply the ETV-
verified technologies based on these market
penetration scenarios. Because this analysis only
considers large facilities located in non-attainment
areas, the number of facilities with the potential to
apply the technologies is much larger. Specifically,
the estimates do not include smaller facilities,
facilities in areas that meet the NAAQS, or
new facilities that could apply the ETV-verified
technologies. The estimates also do not include
          PROJECTED NUMBER OF LARGE
      FACILITIES IN NON-ATTAINMENT AREAS
        THAT WOULD APPLY ETV-VERIFIED
    MtMnJOiM
Market Penetration
                           Number of Facilities
                                   36
                                   90
           facilities that would require additional control if
           EPA's proposed revisions to the NAAQS (71 FR
           2620) are finalized.

           Pollutant Reduction Outcomes
           U.S. EPA (2005h) estimated that the 358
           facilities included in ETV's market estimate
           emitted 381,400 tons of PM2S in 2001. Pollutant
           reductions from the application of baghouse
           technologies vary based on a number of factors,
           including gas velocity, particle concentration,
           particle characteristics, and cleaning  mechanism.
           Design efficiencies for new baghouse devices are
           between 99% and 99.9%, whereas older models
           have actual operating efficiencies between 95%
           and 99.9% (U.S. EPA, 2003d, 2003k, 20031).
           Also, although removal efficiency was not a
           parameter in the verification tests, data in the
           verification reports indicate that the  ETV-verified
           technologies removed greater than 99.99% of
           PM2 s under the test conditions. The ETV results
           accurately reflect PM2S penetration of the media,
           but overall baghouse efficiencies are a function
           of both media penetration and leaks  through
           components of the baghouse other than the bags.
           According to an EPA OAQPS expert, however,
           it is possible that ETV-verified filtration products
           would cause fewer bag malfunctions  and remove
           more PM2 s  over a longer period of time than
           conventional products (Bosch, 2006).
               Exhibit 2.1-4 shows estimated PM2S
           reductions from application of the ETV-verified
           technologies at large facilities in non-attainment
           areas and two market penetration scenarios,
           10% and 25%. To estimate these reductions,
           ETV used data from U.S. EPA (2005g, 1999b,
                   ESTIMATED POLLUTANT REDUCTIONS
                      AT LARGE FACILITIES IN NON-
                     ATTAINMENT AREAS FROM ETV-
                             ' BAGHOUSE F-
                               PRODUCT
acuities
                 Market
                 Penetration
                 10%
                                                                          Annual PM25 Reduction
                       (tons per year)
                              3,000
                              7,600
                            ^^
Values rounded to two significant figures
12 For purposes of these statistics, ETS considers baghouses of 50,000 to 250,000 acfm to be medium and those above 250,000 acfm to be
  large.

20                                                   Environmental Technology Verification (ETV) Program

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                                                                      2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
and 1993) to estimate that baghouse technologies
account for approximately 8% of total nationwide
PM2 s emissions from point sources and applied
this percentage to the 381,400 tons emitted by
large facilities in non-attainment areas. ETV then
assumed that these facilities have existing baghouses
with a removal efficiency of 95% and that applying
ETV-verified filtration products would increase
their efficiency to 99.9%. There is substantial
uncertainty involved in applying these assumptions,
because data are not available to estimate overall
baghouse removal efficiency using the ETV-verified
filtration products or the efficiency of existing
baghouses at the selected facilities. The resulting
estimates likely are conservative (low) because some
of the facilities might not have existing controls
in place. They also do not account for additional
reductions that would occur if EPA's proposed
revisions to the NAAQS (71 FR2620) are finalized.
Finally, with approximately 100,000 baghouses
in the United States, the total number of facilities
with the potential to apply the technologies is much
larger. Using the same assumptions and national
emissions data from U.S. EPA (2005g), ETV
estimates that  pollutant reductions could be up to
43,000 tons  per year at 25% market penetration if
the ETV-verified filtration products were applied
nationwide.  Appendix A describes the methods and
assumptions used in these estimates in greater detail.

Human Health  and Environmental Outcomes
Based on data from EPA's Regulatory Impact
Analysis (RIA) for the 1997 NAAQ_S (U.S.
EPA, 1997b), the ETV Program estimated the
human health outcomes that would be associated
with the PM2 s reductions shown in Exhibit
2.1-4. Appendix A describes the methods and
assumptions used in these estimates in greater
detail, but the estimates assume a straight-line
relationship between pollutant reductions and
reductions in health effects estimated in the RIA.
This assumption is most likely a simplification of
the actual relationship between these two factors
for a number of reasons discussed in Appendix A.
   Exhibit  2.1-5 shows the estimated human
health outcomes  based on the methods described
in Appendix A. These outcomes include avoided
cases of premature mortality, acute and chronic
illnesses, hospital visits, and lost work days.
Exhibit 2.1-5  includes upper- and lower-bound
estimates because the RIA presents both upper-
and lower-bound data. The estimates likely are
conservative (low) because they are based on the
conservative estimates of pollutant reductions,
which only account for pollutant reductions at
large facilities in non-attainment areas. ETV
estimates that the number of premature deaths
avoided would be up to 380 per year in the
upper bound at 25% market penetration if the
ETV-verified filtration products were applied
nationwide.
   In addition to the benefits shown in Exhibit
2.1-5, there are other, unquantified health
              gammm wmms £
                      ameM lEUW^/MK
          iTifef rwt JW» S/**:^»*f^^^^^^H
                           'saMfaism
      PM2 ..-Related
                              Market Penetration
      Outcomes PerYear         10%
                    Upper Bound
      Premature Deaths
      Chronic Bronchitis
25%
      Hospital Admissions—
      all respiratory (all ages)
      Hospital Admissions—
      congestive heart failure
      Hospital Admissions—
      ischemic heart disease
      Acute Bronchitis
      Lower Respiratory Symptoms
      Upper Respiratory Symptoms
      Work Loss Days
      Minor Restricted Activity Days

     ^^^^^^^^^^^^^^1
      Premature Deaths
      Chronic Bronchitis
      Hospital Admission:
      all respiratory (all ages)
      Hospital Admissions-
      congestive heart failure
      Hospital Admissions—
      ischemic heart disease
      Acute Bronchitis
      Lower Respiratory Symptoms
      Upper Respiratory Symptoms
      Work Loss Days
      Minor Restricted Activity Days
      Values rounded to two significant figures
Environmental Technology Verification (ETV) Program
                                              21

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
            he NAAQS for PM15] means that
            owners/operators of new or existing
baghouses will have to consider fine  participate
removal effectiveness when making decisions on
purchasing filter media. Credible information on
the performance of filter media, at reasonable cost,
will assist them in their selection process. Such
information will also provide valuable guidance for
consultants and state and local agencies reviewing
baghouse permit applications."
-ETSandRTI,200le

benefits associated with reductions in PM2 s,
including avoided changes in pulmonary function,
morphological changes, altered host defense
mechanisms, cases of cancer, cases of other
chronic respiratory diseases, and cases of infant
mortality (U.S. EPA, 1997b). PM2.S reductions
can also result in nonhealth-related environmental
benefits, including improved visibility and
avoided damage to materials and ecosystems.
The ETV Program's estimates under "Economic
and Financial Outcomes," below, include
visibility benefits and consumer cleaning cost
savings, which are the avoided costs of cleaning
households that would otherwise be soiled by
PM2 s and represent part of the value of avoided
damage to  materials.

Regulatory Compliance Outcomes
As discussed in Section 2.2.1, EPA has identified
39 areas of the country, with a total population
of 90 million, that exceed the NAAQS for
PM2 s. Although controls on other pollutants,
such as those required under the 2005 Clean
Air Interstate Rule, will help some areas meet
the PM2 s standards, EPA anticipates that many
states will require emission controls on large
stationary sources of PM2S (70 FR 65984). The
ETV-verified baghouse filtration products can
be used to meet  these requirements. In addition,
         t least one customer ... made his work
         with permitting easier by running our
materials through the ETV testing process ..."
—Clint Scoble, BWF America (Scoble, 2006)

the verification data can assist facilities and state
and local agencies in evaluating the technologies'
effectiveness for meeting these requirements (see
quote at top left). The availability of ETV data
also has facilitated the permitting process for users
(see quote at bottom left).
    ETV also supports state and local air
pollution rules. On November 4,2005, the
California South Coast Air Quality Management
District (SCAQMD) adopted Rule 1156, which
encourages the use of ETV-verified baghouse
fabrics to control particulate emissions from
cement manufacturing facilities. Paragraph
(e)(7) of the rule allows facilities that use ETV-
verified products in their baghouses to reduce the
frequency of compliance testing from annually to
every five years (SCAQMD, 2005; Pham, 2006).
EPA's OAQPS plans to issue a memorandum to
EPA regional air divisions (see quote top of next
page) that:

*   Outlines the advantages of the ETV and
    ASTM protocols for baghouse filtration
    products
*   Indicates that EPA will consider ETV
    protocols in future federal regulations
    wherever appropriate
*   Requests that regional offices encourage and
    aid state and local pollution control agencies
    to use the ETV protocol
*   Encourages the adoption of rules similar to
    that issued by SCAQMD (Bosch, 2006).

Economic  and Financial Outcomes
In addition to personal and societal impacts, the
human health  outcomes discussed above also
have an economic benefit. The ETV Program
estimated the nationwide economic benefits
associated with the human health outcomes
shown in Exhibit 2.1-5 based on the upper- and
lower-bound economic estimates provided in the
RIA for the 1997 NAAQ.S (U.S. EPA, 1997b).
Based on the same data, ETV also included
benefits associated with visibility improvements
and consumer cleaning cost savings.
    Exhibit 2.1-6 presents the economic
estimates.13 Appendix A presents the assumptions
13 These estimates are subject to the same limitations discussed for the human health outcomes. However, they likely are conservative (low),
   as discussed in Appendix A. For example, they are in 1990 dollars.

22                                                    Environmental Technology Verification (ETV) Program

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                                                                    2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
         ESTIMATED ECONOMIC BENEFITS
          FROM ETV-VER/F/ED BUGHOUSE
         FILTRATION PRODUCTS AT LARGE
       FACILITIES IN NON-ATTAINMENT AREAS
     Market
     Penetration
     10%
     25%                   81
     Values rounded to two significant figures
Million dollars per years
Lower       Upper
Bound       Bound
   13           72
used in this analysis in greater detail. As for
human health outcomes, these economic estimates
likely are conservative (low) because they only
account for pollutant reductions at large facilities
in non-attainment areas. ETV estimates that the
economic benefits would be up to $2.5 billion
per year in the upper bound at 25% market
penetration if the ETV-verified filtration products
were applied nationwide. Additional economic
benefits could result from the prevention of other
human health and  environmental outcomes
discussed above.
    In addition, rules like SCAQMD's Rule 1156
could have significant financial benefits for users
of the verified products. Reducing compliance
tests from annual to every five years  could save
each user $5,000 per avoided compliance test, or
$20,000 per five year cycle (Bosch, 2006). Also,
as discussed in "Technology Acceptance and Use
Outcomes," filters that produce lower pressure
drops could reduce facility operating costs for the
user.

Scientific Advancement Outcomes
The development of the ETV protocol for
baghouse filtration products has promoted
standardization and consistency in performance
evaluation. The ETV protocol has been adopted
as ASTM D6830 "Characterizing the Pressure
Drop and Filtration Performance of Cleanable
Filter Media" (U.S. EPA, 2004a). ISO, a
worldwide voluntary standards organization, also
has proposed the ETV testing protocol as their
standard and it is progressing through the ISO
adoption/approval  process.
    In addition, the development of the protocol
and publication of verification results has provided
and will continue to provide valuable scientific
             e plan to ... issue a memorandum
             from Steve Page, our OAQPS Director,
  to all EPA Regional Offices and State Directors
  which endorses the use of verified baghouse
  filter-media and encourages its future use in both
  permits and in new/revised regulations wherever
  appropriate."
           ther air pollution  monitoring and control
           technologies have also been verified by
  ETV and we hope to soon expand their applicability
  and use by permitting authorities and regulators
  nationwide."—John Bosch, EPA OAQPS (Bosch,
12006)

information to facilities, vendors, and state and
local agencies (see quote below). For example, over
the last three years the ASTM method has been
used for over 100 tests. These tests have been used
to screen media during early stage development
of new media and as a quality control test for
commercial lots of fabric (McKenna, 2006).

Technology Acceptance and Use Outcomes
In 2005, fabric filter industry sales to one industry
sector, the U.S.  power plant industry, were
expected to be $630 million. Vendors have found
the ETV data useful in competing in this robust
                                   ndustry vendors, new technology developers,
                                   state regulators,and environmentalists ...
                             all worked together to generate the protocols
                             .... It benefited industry, because it reduced the
                             risk for applications of technology.They were
                             able to see real results, not vendor projected
                             results—results that were tested to minimize the
                             risk and allow them to move forward at a much
                             more  rapid pace. It benefited the developers by
                             promoting technology acceptance.The education
                             process and the balanced protocol development
                             gave them a truly beneficial test to determine
                             what their technology could or could not do. It
                             benefited the state regulators because the testing
                             provided data on performance, applications, and
                             operation and maintenance. It made it a little easier
                             to obtain permits."—Robert Bessette, President of
                             the Council of Industrial Boiler Owners (U.S. EPA,
                             2004a)
                           vl
Environmental Technology Verification (ETV) Program
                                                                        23

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
          ore successfully used the program to win
          business in the marketplace. Customers
greatly appreciate the credible and high quality
data from U.S. EPA."—Wilson Poon.W.L Gore and
Associates (Poon, 2002)
market (see quote next page). For example, ETV
verification results contributed to purchasing
decisions in the following two instances:

*  A steel producer used the ETV verification
    test data in replacing its 2,000 fabric filter
    bags used for reducing its electric arc furnace
    emissions. The facility used the ETV data
    in selecting a verified fabric filter that would
    provide a lower pressure drop, resulting in a
    lower operating cost.
                                        *  An electrical power generator used the ETV
                                            verification test data in replacing its 9,000
                                            fabric filter bags. The facility used the ETV
                                            data to identify differences in performance,
                                            in particular pressure drop, associated with
                                            candidate technologies, and ultimately selected
                                            an ETV-verified technology based on the
                                            verification data (Mycock et al., 2002).
                                            Also, some of the vendors participating
                                        in the program have submitted materials for
                                        multiple rounds of testing, for example, upon
                                        development of a new product. In one case, a
                                        vendor "re-verified" the same product after the
                                        initial verification expired.14 The continuing
                                        participation of the vendors suggests that they are
                                        benefiting from the program.
                                 ACRONYMS USED IN THIS CASE STUDY:
 acfm

 APCT

 cm w.g.

 g/dscm

 ISO

 NAAQS

 OAQPS
actual cubic feet per minute

ETV'sAir Pollution Control Technology Center

centimeters water gauge

grams per dry standard cubic meter

International Standards Organization

National Ambient Air Quality Standards
PM

PM

PM,
10
  2.5

RIA

SCAQMD

SIP
ERA's Office of Air Quality Planning and Standards    Hg/m3
particulate matter

fine PM with a nominal aerodynamic diameter of
10 micrometers or less
fine PM with a nominal aerodynamic diameter of
2.5 micrometers or less
Regulatory ImpactAnalysis

South Coast Air Quality Management District

State Implementation Plan

micrograms per cubic meter
14 The baghouse filtration products verification statements are valid for three years from the date of verification.

24                                                        Environmental Technology Verification (ETV) Program

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                                                                   2.2
                Continuous  Emission
                         Monitors  (CEMs)
                                         for  Mercury
          The ETV Program's Advanced
          Monitoring Systems (AMS)
          Center, operated by Battelle under
          a cooperative agreement with EPA,
          has verified the performance of
seven continuous emission monitors (CEMs) for
measuring mercury emissions. Mercury is a toxic,
persistent pollutant that, after deposition from
the atmosphere, accumulates in the food chain,
particularly in fish. Mercury can cause adverse
neurological health effects, particularly in the
unborn children of mothers who eat food with
significant mercury accumulation. To help address
the health effects of mercury, EPA recently issued
the Clean Air Mercury Rule (CAMR). This
rule requires coal-fired power plants, the largest
source of human-generated mercury emissions in
the U.S., to reduce mercury emissions. The rule
also will require power plants to monitor their
emissions using technologies like those verified by
the ETV Program.
   Based on the analysis in this case study, ETV
verification of mercury CEMs has:

*  Contributed to advancing mercury monitoring
   technology and resulted in improvements in
   monitors by the participating vendors
*  Helped inform the development of the
   CAMR and could assist in future rule
   refinements
*  Helped small vendors compete in the
   marketplace
*  Involved significant collaboration with state
   agencies (e.g., Massachusetts) and other
   federal agencies (e.g., the Department of
   Energy). This collaboration resulted in the
   sharing of scientific expertise among the
   agencies and enabled smaller vendors to
   participate in the tests.
   The ETV Program also projects the following
benefits:

*  ETV-verified mercury CEMs or monitors
   improved as a result of testing could be
   applied at the approximately 340 utilities that
   EPA estimates would use CEMs to meet
   monitoring requirements under the CAMR.
*  The verified monitors could be applied at
   other facilities (e.g., incinerators), by state
   agencies, or in research efforts addressing
   mercury chemistry or control.
*  The information provided by the verified
   monitors will ultimately assist in achieving
   mercury emissions reductions, with associated
   human health, environmental, and economic
   benefits.
  2.2.1 Environmental, Health, and
  Regulatory Background
EPA estimates that total annual global mercury
emissions, including both natural and human-
generated, range from roughly 4,400 to 7,500
Environmental Technology Verification (ETV) Program
                                   25

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
tons per year. Human-generated emissions in the
U.S. account for about 3% of this total (U.S. EPA,
2005e). Coal-fired power plants are the largest
source of human-generated mercury emissions in
the U.S., accounting for about 40% of nationwide
emissions  in 2003 (U.S. EPA, 2005e; 2005f).
    Mercury is "a toxic, persistent pollutant
that accumulates in the food chain." (U.S. EPA,
2005e) Although concentrations in the air
usually are low (i.e., a few nanograms per cubic
meter), mercury reacts slowly in the atmosphere
and can be transported thousands of miles
before it is deposited to water or soil. When
atmospheric mercury reaches rivers, lakes, and
estuaries, it can be  transformed into methyl
mercury, a highly toxic form that accumulates
in fish tissue. Consumption offish that have
accumulated mercury is the primary route of
human exposure to methyl mercury and represents
a particular concern for women of childbearing
age. Developing fetuses are sensitive to the toxic
effects of methyl mercury, and children exposed to
methyl mercury before birth can be at increased
risk for adverse neurobehavioral effects, such as
poor performance on tasks that measure attention,
fine motor function, language skills, visual-spatial
abilities and verbal memory (U.S. EPA, 2005e;
Battelle, 2004a). Consumption offish or other
food containing high levels of mercury can also
pose a risk to adults, with effects including failure
of muscle  control, blurred vision, slurred speech,
hearing difficulties, blindness, deafness, and death
(U.S.EPA,2005f).
    To help address the risks associated with
mercury emissions from coal-fired power plants,
EPA issued the CAMR on March 18,2005. The
CAMR limits mercury emissions from new and
existing coal-fired power plants and creates a
market-based cap-and-trade program that will
reduce nationwide  utility emissions of mercury.
Under a cap-and-trade program, coal-fired power
plants that reduce emissions more than required
receive allowances. They can then trade these
allowances to sources that are unable to meet
the requirement, or bank them for future use.
This approach represents an economically more
efficient method for reducing total emissions than
a traditional technology standard and emissions
limit. The ability to trade creates financial
incentives for sources to use innovative, low-cost
methods to reduce emissions and improve the
performance of emission control equipment. The
ability to bank allowances for future use also can
result in early reductions of mercury (U.S. EPA,
2005e).
   A cap-and-trade program, like that under the
CAMR, must include stringent monitoring of
emissions  to ensure that reductions occur, allow
for tracking progress, and lend credibility to the
trading component of the program. Therefore, the
CAMR requires coal-fired utilities that emit more
than 29 pounds of mercury per year to collect
mercury emission data continuously. To collect
this data, the utilities can use either CEMs like
those verified by the ETV Program or another
long-term mercury sampling method, a sorbent
trap monitoring approach. The CAMR sets
performance requirements for these monitoring
technologies, including standards for monitoring
total mercury with CEMs (70 FR 28606). These
requirements include the following:

*  Initial and daily calibration error tests with
   a performance specification of 5.0% of span
   for the initial daily test with an alternate
   specification for span values of 10 micrograms
   per standard cubic meter (|ag/scm) of an
   absolute difference less than or equal to 1.0
   |_ig/scm
*  Initial and quarterly 3-point linearity tests
   with a performance specification of 10% of
   the reference concentration with an alternate
   specification for span values of 10 |_ig/scm of
   an absolute difference less than or equal to 1.0
   |_ig/scm
*  An initial cycle time test with a maximum of a
   15-minute cycle time
*  Initial and annual relative accuracy test audits
   with a requirement to achieve a relative
   accuracy of 20.0% or less with an alternate
   specification for stack concentrations less than
   5.0 |_ig/scm of an absolute difference less than
   or equal to 1.0 |_ig/scm
*  An initial bias test
*  Initial and weekly system integrity tests with a
   performance specification of 5.0% of span.
26
   Environmental Technology Verification (ETV) Program

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                                                                        2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
   2.2.2  Technology Description
CEMs for mercury are a relatively new
technology category. They offer an advantage
over conventional laboratory techniques (e.g., the
Ontario Hydro or "OH" method) in that they can
provide real-time or near real-time monitoring
results. Because they provide continuous results
or frequent results through sequential readings
at intervals of several minutes, they avoid the
delay, labor, and cost associated with laboratory
methods.
    Typically, CEMs determine elemental
mercury vapor by atomic absorption (AA), atomic
fluorescence (AF), or plasma atomic emission
(AE).  CEMs also use aqueous reagents or heated
catalysts to reduce  oxidized forms of mercury
to elemental mercury for detection, allowing
measurement of total mercury. Although some
CEMs measure total mercury only, others allow
separate measurement of the elemental and
oxidized forms (Battelle, 2004a).
    The seven CEMs for mercury that have been
verified to date by the ETV Program include
examples of each of these detection and reduction
approaches, some reporting on  a continuous  basis
and some on a semi-continuous basis. Exhibit
2.2-1 identifies the ETV-verified monitors and
              provides a description of each. The verification
              reports (Battelle, 2001a, 2001b, 2001c, 2001d,
              2003a, 2003b, 2003c, 2003d, 2003e) can be found
              at http://www.epa.gov/etv/verifications/vcenterl-
              11.html.
                  Verification testing was conducted in two
              rounds. In the first round, four of the technologies
              were tested under  conditions simulating (a)
              coal-fired flue gas  and (b) municipal incinerator
              flue gas. The tests  took place at a pilot-scale
              incinerator in Research Triangle Park, North
              Carolina, over a three-week period. In the
              second round, five technologies (including two
              of the technologies tested in the first phase)
              were evaluated at a full-scale waste incinerator
              in Oak Ridge, Tennessee. The testing took place
              over several weeks of continuous operation.
              In addition, the  ETV Program is currently
              conducting a third round of testing at a coal-fired
              power plant (the box next page identifies CEM
              and sorbent-based sampling technologies included
              in this third round).
                  In each round  of verification testing, the
              Ontario Hydro (OH) method was used as the
              reference method for establishing the performance
              of the tested technologies. The performance
              parameters verified included the following:
              accuracy relative to the OH method, correlation
                 ETV-VERIFIED CEMs FOR MERCURY (FiRsrTwo ROUNDS OFTESTING)
      Technology
      Envimetrics,Argus-Hg 1000 Mercury CEM
      Nippon Instruments Corporation, DM-6/
      DM-6P Mercury CEM
      Nippon Instruments Corporation,AM-2
      Elemental Mercury CEM
      Nippon Instruments Corporation, MS-1/
      DM-5 Mercury CEM (verified in 2001 and
      2003)
      Ohio Lumex, Ltd., Lumex Mercury CEM
      OPSIS AB, HG-200 Mercury CEM
      PS Analytical, Ltd., Sir Galahad II Mercury
      CEM (verified in 2001 and 2003)
           •              ^H
      Sources: Battelle, 2001 a, 2001 b, 2001 c, 2001 d
                          Description
 Uses AE spectroscopy with a proprietary catalytic converter that reduces molecular
 forms of mercury to atomic mercury.Total mercury can be measured during
 automatic operation, or both total and elemental mercury can be measured when
 manually operated.
 Uses cold vapor AA with a catalytic process to measure total mercury.

 Uses cold vapor AA, with a distilled water scrubbing trap for removal of any
 oxidized mercury species, to measure elemental mercury.
 Uses cold vapor AA to provide separate and continuous measurements of elemental
 and oxidized mercury, which are separated using a wet scrubbing and chemical
 reaction system.
 Uses cold vapor AA to provide separate and continuous measurements of elemental
 and total mercury, with catalytic pyrolysis to decompose oxidized mercury to
 elemental mercury for total mercury measurement.
 Uses a double-beam photometer to measure total or elemental mercury, with
 a thermo-catalytic converter that forms elemental mercury from any oxidized
 mercury compounds to measure total mercury.
 Uses AF to provide separate and continuous measurement of elemental and total
 mercury, with a proprietary aqueous reagent to convert oxidized mercury to
 elemental mercury for total mercury measurement.
2003a, 2003b, 2003c, 2003d, 2003e.

Environmental Technology Verification (ETV) Program
                                                              27

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
MERCURY MONITORING TECHNOLOGIES
INCLUDED IN THE THIRD ROUND
OF ETVVERIFICATION
    Tekran Instruments, mercury CEM
*  Thermo, mercury CEM
*  Environmental Supply Company, mercury
    sorbent trap
*  Apex Instruments, mercury sorbent trap

with that method, precision (i.e. repeatability),
bias, calibration/zero drift, response time,
interferences, data completeness, and other
operational factors.
                                         Exhibit 2.2-2 summarizes some of the
                                     performance data for the verified technologies.
                                     Because the ETV Program does not compare
                                     technologies, the performance results shown
                                     in Exhibit 2.2-2 do not identify the vendor
                                     associated with each result and are not in the same
                                     order as the list of technologies in Exhibit 2.2-1.
                                         The ETV Program found that the average
                                     relative accuracy for the monitors ranged from
                                     11.2% to 76.5%. A result of 0% indicates perfect
                                     accuracy relative to the reference mercury
                                     concentration. The relative precision ranged from
                                     1.8% to 43.3%. A result of 0% indicates perfect
                                     precision. With one exception, monitor bias
                                     ranged from -7% to 14.6%. The response times,
                         PERFORMANCE OF ETV-VER/F/ED OEMs FOR MERCURY^
                    Average
                    Relative     Relative     Response
     Technology   Accuracy    Precision    Time (95%)       Bias
                                                  First Round
                   58.2 to 71%
                     (total
                    mercury)
                    14 to 23%
                   (elemental
                    mercury)
                  20.6 to 32.8%   1.8 to 24.7%
                     (total
                    mercury)
                     59.8%
                     (total
                    mercury)
                     11.2%
                     (total
                    mercury)
                     76.5%
                     overa
                                                         Correlation
                                                           (slope,            Data
                                                       intercept,r2) (I)   Completeness
                           30 to 100
                            seconds

                         One 13-minute
                             cycle
                          One 5- to 6-
                          minute cycle
-44.5 to -20.5%   Slope: not reported      Not estimated
              Intercept: not reported
              r2:0.621
    07%
 -4.9 to -0.3%
13.2 to 39.1%   3.7 to 23.9%  35 to 50 seconds       -7%
   (total
 mercury)

                              Second Round
                          One 5- to 6-      2.8 to 6.9%
                          minute cycle
             9.2 to 17.3%   2 to 3 minutes
             10.1 to 22.1 %  One 7-minute
                            cycle
                               9.1 to 10.9%
                           2 minutes
 0.0 to 6.6%
 0.3 to 14.6%
 0.0 to 13.6%
                                               cycle
Slope: 0.885
Intercept: -0.212
r2:0.973
Slope: 0.681
Intercept: 2.492
r2:0.978
Slope: 0.607
Intercept: 3.92
r2:0.938
Slope: 0.4973
Intercept: 6.8904
r2:0.875
Slope: 0.899
Intercept: 2.4969
r2:0.987
Slope: 0.3404
Intercept: 9.4121
r2:0.8393
Slope: 0.8347
Intercept: 3.5033
r2:0.953
                               12.5 to 43.3%   One 5-minute    Not evaluated   Slope: 0.3559
                                                      Intercept: 8.1695
                                                      r2:0.935
     (I) Correlation data shown are for total mercury, except technology B, where results shown are for elemental mercury.

     Sources: Battelle, 2001 a, 2001 b, 2001 c, 2001 d, 2003a, 2003b, 2003c, 2003d, 2003e.
15 Because the ETV Program does not compare technologies, the performance results shown in Exhibit 2.2-2 do not identify the vendor
   associated with each result and are not in the same order as the list of technologies in Exhibit 2.2-1.
28
                                        Environmental Technology Verification (ETV) Program

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                                                                      2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
which measure instrument response to a sudden
change in mercury concentration, ranged from 30
seconds to within approximately 13 minutes. The
ETV Program used linear regression analysis to
evaluate correlation  of the monitor results to the
OH method results. For total mercury, the slope
values ranged from 0.3404 to 0.899; the intercept
values ranged from 2.492 to 9.4121 micrograms
per dry standard cubic meter; and the r2 values
ranged from 0.621 to 0.987.16 A higher r2 value
indicates a higher correlation with the standard
test method over the range of concentrations
tested. The price of the monitors ranged from
$30,000 to $70,000 at the time of testing
(Battelle, 2001a, 2001b, 2001c, 2001d, 2003a,
2003b, 2003c, 2003d, 2003e).
   2.2.3  Outcomes
The market for the ETV-verified CEMs includes
coal-fired utilities that must continuously monitor
mercury emissions (i.e., those that emit more than
29 pounds of mercury per year) to meet CAMR
requirements. Accordingly, the ETV Program used
data from a technical background document for
the CAMR (U.S. EPA, undated) to estimate this
market. This document estimated that 342 of the
685 facilities required to monitor continuously would
choose CEMs, as opposed to another technology.
The ETV Program used this estimate to represent
the potential market for the verified monitors.

Regulatory Compliance Outcomes
As  noted in Section 2.2.1, CAMR mandates
certain performance testing and standards for
CEMs. Although the ETV verification tests
and test conditions17 were not identical to those
required by the final rule, nor are the results all in
a form directly comparable to those of the rule's
performance specification, some comparisons to
the CAMR requirements are possible. Firstly, six
of the seven ETV-verified CEMs provide total
mercury results, as required by the rule. Secondly,
the verified CEMs either provide real-time
One of the test locations for mercury CEM verification

monitoring data or have cycle times of 3 to 13
minutes, which is less than the CAMR maximum
15 minute cycle time. Finally, when tested on
simulated coal-fired flue gas, two of the monitors
provided relative accuracy for total mercury of
13.2% and 20.6%, respectively, close to or better
than the relative accuracy required by the CAMR.
    Since these results meet or very nearly meet
the CAMR requirement, it is possible that at least
some of the ETV-verified monitors, or similar
monitors improved by the vendors as a result of
ETV testing, could be used to meet the CAMR
monitoring requirements. It also is important to
note that the ETV Program is conducting a third
round of CEM testing at a coal-fired power plant,
under conditions that more closely simulate those
experienced when the monitors are used for rule
compliance (U.S. EPA, 2004a; Battelle, 2004a).
Depending upon how well the monitors perform
during this third round, these monitors could also
be candidates to meet the CAMR requirements.
Therefore, any of the 342 coal-fired utilities
discussed above ultimately could use ETV-verified
CEMs to comply with the CAMR.18
    In addition to these facilities, other facilities
could use the verified technologies to meet other
regulatory requirements. Such facilities include
16 Slope and intercept are measures of the relationship between analyzer response and the reference method value. The degree to which
   the slope deviates from one and the intercept deviates from zero are indicators of the monitor's accuracy. The r2 is a measure of how well
   observed data fit a linear relationship. Values of r2 range from 0 to 1, with higher values indicating a better fit. Thus, a higher r2 value
   indicates a higher correlation with the standard test method over the range of concentrations tested.
17 Most notably, the monitors were tested on incinerator flue gas and simulated (not actual) coal-fired gas.
18 U.S. EPA (undated) estimated 342 of 685 utilities would use CEMs, while the rest would use sorbent traps. While all 685 ultimately
   could use ETV-verified technologies, to be conservative, ETV chose 342 as its estimate of the number of facilities that could use ETV-
   verified CEMs.
Environmental Technology Verification (ETV) Program
                                              29

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
municipal and hazardous waste incinerators that
emit mercury. State regulatory agencies also could
use the monitors to investigate specific sources.
The verification data can assist facilities and state
and local agencies in evaluating the technologies'
effectiveness in these applications. For example,
in issuing a recent permit for a cement facility, the
Florida Department of Environmental Protection
required the facility to install a mercury CEM.
The permit requires that the CEM either meet
the state's performance standard or be ETV
verified (Florida Department of Environmental
Protection, 2006).

Pollutant Reduction, Environmental,
Human Health, and Economic Outcomes
As discussed in Section 2.2.1, monitoring data
are integral to achieving reductions under a cap-
and-trade program like that established under the
CAMR. The CAMR, when fully implemented,
will reduce utility mercury emissions from 48 tons
per year to 15 tons per year (U.S. EPA, 2005e).
These reductions would result in human health
benefits such as preventing intelligence quotient
(IQ) losses in children of people consuming
recreationally caught fish. EPA estimated the
economic value of avoiding these IQ_losses at
$200,000 to $3 million per year in 1999 dollars,
depending on the assumptions applied and
the discount rate. EPA also noted that there
would be non-quantifiable benefits that include
avoiding adverse cardiovascular and ecosystem
effects (70 FR 28606). The use of ETV-verified
CEMs ultimately will assist with successful
mercury emissions  reductions, with significant
environmental, human health, and economic
benefits.

                                            ^v
         .S. EPA has organized and conducted test
         programs  for the purposes  of evaluating
continuous mercury emissions monitoring systems
at both a pilot plant level as well as at  commercially
operating power plants. Since initially participating
in the  U.S. EPA-ETV Program, Horiba-NIC has
been an active participant in these test programs
.... Horiba's instrument has benefited from
design improvements as a result of each of the
testing programs ..."—Dean Masropian, Horiba
Instruments, Inc. (ICAC, 2005)
Scientific Advancement Outcomes
ETV verification of mercury CEMs has led to
improvements in monitoring technology. For
example, two vendors (Envimetrics, Inc. and Ohio
Lumex) participated in ETV verification with
newly developed commercial CEMs, and reported
that the field testing had been highly valuable
and informative. These and other vendors used
the test results to improve their CEMs (see quote
below left) (Battelle, 2004a; U.S. EPA, 2004a;
ICAC, 2005). For another vendor, the ETV test
results  contributed to the development of another
mercury CEM technology, a system using a dry
catalyst to convert oxidized mercury to elemental
mercury (Stockwell, 2006).
    ETV verification results also contributed to
the scientific and technology analyses that EPA
performed in support of the CAMR. ETV test
results  were included in the EPA studies  of the
state of monitoring technology that informed
rule development (U.S. EPA, 2003b; U.S. EPA,
2003c). The State of Massachusetts also used the
data from the first two rounds of ETV testing
in its evaluation of the feasibility of mercury
control. The state concluded that monitors
were commercially available and able to meet
the desired 20% relative accuracy standard,
thus contributing to the overall conclusion that
mercury control is feasible and to the state's
decision to develop its own mercury standard
(Massachusetts, 2002). Massachusetts finalized
this standard in 2004, including a requirement
that facilities install CEMs by January 1, 2008
(Massachusetts, 2004).
   In addition, the final CAMR requires
measurement of total vapor phase mercury, but
does not require separate monitoring of speciated
mercury emissions  (i.e., elemental mercury or
oxidized mercury). In issuing the rule, however,
EPA stated that it is important to understand and
monitor the speciation profile of Hg emissions.
EPA stated its commitment to test speciated
mercury monitoring technologies and, if these
technologies are adequately demonstrated, to
consider a proposed rulemaking to reflect changes
in the monitoring requirements within four to
five years after program implementation (70 FR
28606). Because several of the ETV-verified
monitors provide speciated mercury data, the
ETV verification program will help inform the
study associated with this potential regulation.
30
   Environmental Technology Verification (ETV) Program

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                                                                     2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
    ETV verification for mercury CEMs has
involved significant collaboration with other
state and federal agencies, which has helped
to improve the technical quality of the tests
as well as the utility of the results. For the
first round, the Massachusetts Department of
Environmental Protection provided co-funding.
The second round of testing was conducted at a
U.S. Department of Energy (DOE) facility, and
involved partnership with DOE, who provided
major support to conduct the test at their site.
DOE also worked with the vendors, helped
to design the test/quality assurance plan, and
helped to review the verification reports. As
discussed above, the ETV Program is performing
a third round of testing at a  coal-fired utility.
The Connecticut Department of Environmental
Protection provided  $50,000 in cost-share for
this test, and the Illinois Clean Coal Institute
has funded the AMS Center with $170,000 to
support the test. This funding will be used to
offset testing costs so that smaller vendors can
participate in the test (U.S. EPA, 2004a).

Technology Acceptance and Use Outcomes
ETV verification has resulted in sales of mercury
CEMs, assisting small U.S. companies to compete
in the marketplace (see quote top right). The
vendor quoted also stated that, since they are
a small company, ETV verification gave them

                                                  nvimetrics has found the ETV Program
                                                  to be very valuable in the whole process
                                          of developing instrumentation. Envimetrics started
                                          out as an SBIR [Small Business Innovative Research]
                                          company using EPA research grants to develop their
                                            chnology.They then received some state funding
                                          br commercialization.The last piece of the puzzle
                                          was for the ETV Program to provide them feedback
                                          and exposure for their product ... for a small
                                          company, one cannot buy the kind of exposure that
                                          one gets by participating in the ETV Program."
                                          —Philip Efthimion, Envimetrics (U.S. EPA, 2004a)
                                        an opportunity to have a level playing field on
                                        which to compete (U.S. EPA, 2004a). Another
                                        mercury CEM vendor, represented by Horiba
                                        Instruments, Inc., reports that participation in
                                        ETV testing has led directly to sales of several
                                        units, including a sale to the operator of the waste
                                        incinerator that was used as the test site for the
                                        second round of ETV verification. Negotiations
                                        are also in progress  with a major utility, and
                                        state agencies have  inquired about use of the
                                        CEM to investigate specific sources. This vendor
                                        routinely calls attention to the ETV test results
                                        in discussions with  prospective customers, and
                                        has publicized the ETV performance results
                                        in presentations at major mercury-related
                                        conferences (Battelle, 2004).
 AA

 AE

 AF
                               ACRONYMS USED IN THIS CASE STUDY:
atomic absorption

atomic emission

atomic fluorescence
 AMS Center  ETV's Advanced Monitoring Systems Center

 CAMR      Clean Air Mercury Rule
CEM        continuous emission monitor

DOE        Department of Energy

IQ         intelligence quotient

OH        Ontario Hydro

pg/scm      micrograms per standard cubic meter
Environmental Technology Verification (ETV) Program
                                                                                      31

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                                                                                   2.3
                                                           Fuel   Cells
            The ETV Program's Greenhouse
            Gas Technology (GHG) Center,
            operated by Southern Research
            Institute under a cooperative
            agreement with EPA, has verified
the performance of two fuel cell technologies
that generate electricity at the point of use. Fuel
cells can reduce emissions of carbon dioxide
(CO2), methane, nitrogen oxides (NOX), carbon
monoxide (CO), and total hydrocarbons (THCs).
CO2 and methane are greenhouse gases linked
to global climate change. CO, THCs, and the
various compounds in the NOX family, as well
as derivatives formed when NOX reacts in the
environment, cause a wide variety of health and
environmental impacts.
   Available sales data indicate that a capacity
of 15 megawatts (MW) of ETV-verified fuel'
cells have been installed in the United States
since the verifications were completed. Based
on the analysis in this case study, the estimated
benefits of these existing installations include  the
following:

* Emissions reductions of 17,000 tons per year
   of CO2 and 120 tons per year of NOX, with
   associated climate change, environmental,
   and human health benefits. At least 29% of
   the fuel cells are installed in combined heat
   and power  (CHP) applications, potentially
   providing emissions reductions in addition to
   those estimated here.
*  Increased utilization of renewable fuels,
   such as anaerobic digester gas, resulting in
   reductions in the consumption of natural
   resources. Systems that utilize anaerobic
   digester gas represent 2 MW of the currently
   installed capacity and contribute 14,000 tons
   per year of the CO2 reductions estimated
   above.
*  Potential reductions in emissions of other
   greenhouse gases and pollutants, with
   additional environmental and human health
   benefits.
   As the capacity of fuel cells installed increases,
emission reductions and other benefits also will
increase. In fact, based on the analysis in this case
study and assuming annual sales continue at the
same rate as in 2005, the ETV Program estimates
the total installed capacity of ETV-verified fuel
cells will reach 34 MW in the next five years,19
with the following benefits:

*  Emissions reductions of 41,000 tons per year
   of CO2 and 270 tons per year of NOX, with
   associated climate change, environmental,
   and human health benefits. The percent of
   fuel cells installed in CHP applications would
   increase to at least 38%, resulting in even
   greater additional emissions reductions.
*  Utilization of renewable fuels would increase,
   resulting in additional reductions in natural
   resource consumption. Systems that utilize
   anaerobic digester gas represent 5 MW of
19 This estimate includes the 15 MW that the ETV Program estimates have already been installed. It represents 134 fuel cells total.

Environmental Technology Verification (ETV) Program                                                  33

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
    the estimated future capacity and would
    contribute 36,000 tons per year of the CO2
    reductions estimated above.
*  Increasing reductions in emissions of other
    greenhouse gases and pollutants, with
    additional environmental and human health
    benefits.
    In addition, vendors and users estimate that
fuel cell installations can result in cost savings for
the user. Fuel cells also  can provide reliable backup
power to emergency services facilities and shelters
in the event of a natural disaster or other event.
   2.3.1  Environmental, Health,
   and Regulatory Background
EPA estimates that, in 2002, the United States
emitted almost 6.4 billion tons of CO2 and nearly
22 million tons of NOX.20 Electricity generation
is the largest single source of CO2 emissions,
accounting for 39% of the total. Electricity
generation also contributes significantly to NOX
emissions, accounting for 21% of the total (U.S.
EPA, 2004e). A variety of other pollutants also are
emitted during electricity generation, including
CO  andTHCs. Each of these emissions can
have significant environmental and health effects.
Conventional electricity generation also consumes
finite natural resources, with environmental  and
economic repercussions.
   CO2 is the primary greenhouse gas emitted
by human activities in the United States. Its
concentration in the atmosphere has increased
31% since pre-industrial times. As a greenhouse
gas,  CO2 contributes to global climate change.
The Intergovernmental Panel on Climate Change
(IPCC) has concluded that global average surface
temperature has risen 0.6 degrees centigrade
in the 20th century, with the 1990s being the
warmest decade on record. Sea level has risen
0.1 to 0.2 meters in the same time. Snow cover
has decreased by about 10% and the extent and
thickness  of northern hemisphere sea ice has
decreased significantly (IPCC, 2001a). Climate
changes resulting from emissions of greenhouse
gases, including CO2 and methane, can have
adverse outcomes including the following:
*  More frequent or severe heat waves, storms,
   floods, and droughts
*  Increased air pollution
*  Increased geographic ranges and activity of
   disease-carrying animals, insects, and parasites
*  Altered marine ecology
*  Displacement of coastal populations
*  Saltwater intrusion into coastal water supplies.
   Each of these outcomes can result in increased
deaths, injuries, and illnesses (U.S. EPA, 1997a).
Many of these impacts, however, depend on
whether rainfall increases or decreases, which
cannot be reliably projected for specific areas.
Scientists currently are unable to determine which
parts of the United States will become wetter
or drier, but there is likely to be an overall trend
toward increased precipitation and evaporation,
more intense rainstorms, and drier soils (U.S.
EPA, 2000a).
   The various compounds in the NOX family
(including nitrogen dioxide, nitric acid, nitrous
oxide, nitrates, and nitric oxide) and derivatives
formed when NOX reacts in the environment
cause a variety of health and environmental
impacts. These impacts include the following:

*  Contributing to the formation of ground-level
   ozone (or smog), which can trigger serious
   respiratory problems
*  Reacting to form nitrate particles, acid
   aerosols, and nitrogen dioxide, which also
   cause respiratory problems
*  Contributing to the formation of acid rain
*  Contributing to nutrient overload that
   deteriorates water quality
*  Contributing to atmospheric particles that
   cause respiratory and other health problems, as
   well as visibility impairment
*  Reacting to form toxic chemicals
*  Contributing to global warming (U.S. EPA,
   1998; U.S. EPA, 2003J).
   Each of the other pollutants emitted
during electricity generation also can have
significant environmental and/or health effects.
20 Values converted from gigagrams as reported in U.S. EPA (2004e).
34
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                                                                     2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
THCs and CO can contribute to ground-level
ozone formation, and CO can be fatal at high
concentrations (U.S. EPA, 2000b; U.S. EPA,
2005n).
    As discussed in detail in Section 2.3.2, fuel
cells can reduce emissions of greenhouse gases or
pollutants because they use hydrogen, or another
fuel converted to  hydrogen, to generate electricity,
reducing the need to burn fossil fuels. Fuel cells
can be used in vehicles and at stationary locations.
Stationary fuel cells that generate electricity at
the point of use are categorized as distributed
generation (DG)  technologies. These technologies
also can employ heat recovery systems that
capture excess thermal energy and use it to heat
water and/or spaces.  Systems that include this
option are commonly termed CHP systems. As
discussed in detail in Sections 2.3.2 and 2.3.3,
DG and CHP technologies not only have the
potential to reduce emissions, but also to conserve
finite natural resources and utilize resources
that would otherwise be wasted (e.g., anaerobic
digester gas and landfill gas). In recognition  of
these benefits, EPA has established programs such
as the CHP Partnership to encourage the use of
CHP technologies, including those that use  fuel
cells. The CHP Partnership is a voluntary EPA-
industry effort designed to foster cost-effective
CHP projects. The goal of the partnership is
to reduce the environmental impact of energy
generation and build a cooperative relationship
among EPA, the  CHP industry, state and local
governments, and other stakeholders to expand
the use of CHP (U.S. EPA, 2005k).
    One market sector targeted by the CHP
Partnership is wastewater treatment facilities.
Wastewater treatment facilities  generate biogas
from anaerobic digesters. This digester gas can be
used as fuel for a  DG technology like a fuel cell,
instead of released to the atmosphere or burned
using a flare, with a number of benefits for the
facility and the environment (see box at right).
DG technologies also offer an important security
and safety benefit for wastewater treatment
facilities. To help  maintain public health, these
facilities must operate, or come  back on-line
quickly, in the event of a power loss, such as
a catastrophic event or natural disaster. DG
technologies can continue to provide power to
these and other critical facilities in the event of a
utility failure caused by these emergencies (U.S.
EPA, 2006g).
    In a related effort, EPA and many states are
developing and using output-based regulations
for power generators. Output-based regulations
establish emissions limits on the basis of units
of emissions per unit of useful power output,
rather than on the traditional basis of units of
emissions per unit of fuel input. The traditional,
input-based approach relies  on the use of
emissions control devices, whereas output-based
regulations encourage energy efficiency.  Currently
a number of states, including Connecticut and
Massachusetts, have developed output-based
regulations that recognize the energy efficiency
benefits of CHP projects. Regulated sources can
use technologies like the ETV-verified fuel cells as
part of their emissions control strategy to comply
with these regulations. EPA also has developed
resources, such as Output-BasedRegulations: A
Handbook for Air Regulators (U.S. EPA, 2004f), to
assist in developing output-based regulations for
power generators (U.S. EPA, 20051).
    States and localities also are undertaking
efforts to promote the use of fuel cells. Based on
data from Breakthrough Technologies Institute
(2006), agencies in 43 states and the District  of
Columbia have undertaken activities supporting
the use of stationary fuel cells.21 These activities
include the following: demonstration projects,
long-term plans, research support, regulations or

           HP offers many benefits for wastewater
           treatment facilities because it:
     Produces power at a cost below retail
     electricity
  * Displaces purchased fuels for thermal needs
  * Qualifies as a renewable fuel for green power
     programs
  * Enhances power reliability for the plant
  * Offers an opportunity to reduce greenhouse
     gas and other air emissions."
  —EPA's CHP Partnership Web site (U.S. EPA,2006g)
21 Excludes states whose activities are limited to fuel cell vehicles or the production of hydrogen fuel.

Environmental Technology Verification (ETV) Program                                                     35

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
standards, education partnerships, procurement
standards, and business incentives (Breakthrough
Technologies Institute, 2006).
   2.3.2  Technology Description
Fuel cells use hydrogen as the fuel in an
electrochemical process, similar to what occurs
in a battery, that generates electricity (U.S. EPA,
2002b; U.S. DOE, 2006a, 2006b). Unlike a
battery, however, fuel cells can operate indefinitely,
as long as the supply of fuel is maintained (U.S.
EPA, 2002b). Fuel cells consist of two electrodes,
a cathode and an anode, separated by an
electrolyte (U.S. EPA, 2002b; U.S. DOE, 2006a,
2006b). In the ETV-verified fuel cells, hydrogen-
rich fuel reacts with the anode to produce positive
ions and electrons. The positive ions pass through
the electrolyte to the cathode, where they react to
produce water and heat. The electrons must travel
around the electrolyte in a circuit, generating
an electric current (U.S. DOE, 2006a, 2006b).
There are a number of different types of fuel cells,
typically defined by the type of electrolyte used
(U.S.  EPA, 2002b; U.S. DOE, 2006b). The ETV-
verified fuel cells include a polymer electrolyte
membrane (PEM) fuel cell, in which a solid
polymer membrane serves as the  electrolyte, and a
phosphoric acid fuel cell (PAFC), in which liquid
phosphoric acid is the electrolyte (U.S. EPA,
2002b; Southern Research Institute, 1998, 2003c,
2004b).
   Fuel cell technologies incorporate multiple
stacks of paired electrodes. Many fuel cell
technologies, including those verified by ETV,
also incorporate a fuel processor or reformer. This
system converts natural gas or another fuel, such
as biogas, into a hydrogen-rich form for use by the
fuel cell. Because only the fuel processing system
involves combustion, fuel cells generate limited
emissions (U.S. EPA, 2002b; U.S. DOE, 2006a).
The primary byproducts of fuel cells are water and
heat (U.S. DOE, 2006a, 2006b).
   When used in stationary applications to
generate electricity at the point of use, fuel cells
reduce the need to generate electricity from
sources  such as large electric utility plants, which
emit significant quantities of CO2, NOX, and CO.
When coupled with heat recovery systems that
capture excess thermal energy to heat water and/
or spaces, fuel cells also reduce the need to use
conventional heating technologies such as boilers
and furnaces. When well-matched to building
or facility needs in a properly designed CHP
application, fuel cells can increase operational
efficiency and avoid power transmission losses,
thereby reducing overall emissions and net fuel
consumption.
   Fuel cells also can be designed to operate
using biogas from sources including animal waste,
wastewater treatment plants, and landfills. Biogas
is a renewable resource that otherwise goes unused
because it is typically flared or vented to the
atmosphere.
   The first PEM and PAFC fuel cells were
developed in the 1960s and 1970s, respectively
(U.S. EPA, 2002b). Because they have seen
limited commercialization, reliable performance
data are needed on fuel cell technologies.
The ETV Program responded by completing
three verifications for two stationary fuel cell
technologies  (see Exhibit 2.3-1). One of these
technologies is a small PEM fuel cell, sized for
residential-scale use, that operated on natural gas
in the ETV tests. The other is a larger PAFC
technology, sized for  commercial or institutional
use. In the ETV tests, the latter technology
operated on biogas from landfills and a wastewater
treatment plant. Although none of the tests
involved  heat recovery in a CHP application,
ETV did verify the potential for heat recovery in
one of the tests, as discussed below.
   During each test, the ETV Program verified
power production and emissions performance.
In one of the tests, ETV also verified potential
heat production. In two  of the tests (one for each
technology), ETV verified power quality.
   Power production tests measured electrical
power output and electrical efficiency at selected
loads. At full load under normal operations,
electrical efficiencies ranged from 23.8% to
38.0%. In the test where potential heat production
was verified, ETV measured heat production
rate, potential thermal efficiency, and potential
total system efficiency at selected loads. The
potential thermal  efficiency at full load and
normal operation was 56.9%. ETV verified that,
if the heat were recovered, potential total system
efficiency would be 93.8%. In tests at less than full
36
   Environmental Technology Verification (ETV) Program

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                                                                        2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
                                 ETV-VERIFIED FUEL CELL TECHNOLOGIES
                              Electricity
                         Generating Capacity
                           (kilowatts [kW])                      Additional Information
                                            ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^H
                                               Tested at a private residence in Lewiston, New York. Included a fuel
                                               reformulation system to operate using natural gas. Excess power generated
                                               by the fuel cell, but not used by the residence, was directed to the electric
                                               utility grid.
                                               In 1998, tested at municipal solid waste landfills in California and
                                               Connecticut. Included a gas processing unit to operate using landfill gas.The
                                               electricity produced was directed to a local grid system and sold to utility
                                               companies.
                                               In 2003, tested at a wastewater treatment facility in Brooklyn, New York.
                                               Included a gas processing unit to operate using anaerobic digester gas.
                                               Power produced by the fuel cell offset the need to purchase electricity
                                               from the facility's local utility.
     (I) UTC Fuel Cells was known as International Fuel Cells Corporation in 1998, when the first verification was completed.The
     technology has since been renamed as the PureCell ™ 200.
UTC Fuel Cells PC25™
Fuel Cell (I)
     Sources: Southern Research Institute, 1998,2003c, 2004b.
load, electrical efficiencies were lower, but thermal
efficiencies were higher.
    Power quality tests measured electrical
frequency, voltage output, power factor, and
voltage and current total harmonic distortion.
Verified average voltage outputs were 121 volts
(for the technology designed to produce 120 volts)
and 488 volts (for the technology designed to
produce 480 volts). Performance results for the
other power quality parameters are available in
the verification reports, which can be found at the
links below.
    Emissions tests measured emissions
concentrations and rates at selected loads. Verified
CO2 emissions rates ranged from 1.31 to 1.66
pounds per kilowatt-hour (Ibs/kWh). Verified
NOX emissions rates ranged from less than 6.97 x
10 7 to 0.013 Ibs/kWh.22 The ETV Program also
verified concentrations and emissions rates for
other pollutants and greenhouse gases, including
CO, THCs, and methane. Two of the verification
reports, one  for each of the technologies, also
estimated total annual CO2 and NOX reductions.
For the technology tested at a residence, these
reductions were calculated compared to emissions
generated by electricity obtained from the grid.
For the technology operating on anaerobic
digester gas, the basis of comparison also
considered the emissions that were eliminated by
using the gas in the fuel cell system, instead of
                                                 flaring it to the atmosphere. These estimates are
                                                 presented in detail in Appendix B. More detailed
                                                 performance data are available in the verification
                                                 reports for each of the technologies (Southern
                                                 Research Institute, 1998,2003c, 2004b),
                                                 which can be found at http://www.epa.gov/etv/
                                                 verifications/vcenter3-l 7.html and http://www.epa.
                                                 gov/etv/verifications/vcenter3-14.html.
                                                   2.3.3  Outcomes
                                                 The ETV Program used data from Fuel
                                                 Cells 2000's Worldwide Stationary Fuel Cell
                                                 Installation Database (Fuel Cells 2000,2006) to
                                                 estimate the number and capacity of ETV-verified
                                                 fuel cells that have been installed in the United
                                                 States since the verifications were completed. The
                                                 ETV Program used these same data to estimate
                                                 the number and capacity of ETV-verified fuel
                                                 cells that could be installed in the near future.
                                                 ETV extrapolated the number of fuel cells
                                                 installed in year 2005 to each of the next five years
                                                 and added this projection to the capacity currently
                                                 installed.23 Exhibit 2.3-2 shows the resulting
                                                 estimates. Appendix B explains the derivation of
                                                 these estimates in more detail. The ETV Program
                                                 used these capacity estimates to  estimate the
                                                 emissions reduction outcomes shown below.
22 CO2 and NOX emissions results summarized here encompass those from two of the verification reports and cover both technologies. In
   the other report, emissions rates were reported on the basis of operating hours, rather than kWh, and, thus, are not in a comparable form.

Environmental Technology Verification (ETV) Program                                                       37

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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
         PROJECTED NUMBER AND CAPACITY
            OF ETV-VERIFIED  FUEL CELLS
            ESTIMATED TO BE INSTALLED
      Total
      Installed
      Currently
      After Five Years
Number of
 Fuel Cells
   130
  220
Capacity
 (MW)
  15
      Values rounded to two significant figures
Emissions Reduction Outcomes
Emissions reductions from the application of fuel
cell technology depend on a number of factors,
including the electricity demand of the specific
installation, the fuel cell emissions rates, and the
emissions rates of the electric utility power plant
that the fuel cell replaces. These factors vary
geographically and by specific application. Given
this variation, characterizing these factors for
every potential ETV-verified fuel cell application
is difficult. Therefore, ETV used estimates
developed by Southern Research Institute for
the test sites to extrapolate emissions reductions
estimates for current and future installations.
Appendix B describes the Southern Research
Institute estimates and the method for using
these estimates to project nationwide emissions
reductions for the fuel cell capacities shown in
Exhibit 2.3-2.
    Exhibit 2.3-3 shows estimates of annual CO2
and NOX reductions generated using this method
for the fuel cell capacity currently installed and
the projected capacity after five years. In addition
to the CO2 and NOX reductions shown in Exhibit
                            Annual Reduction
                              (tons per year)
      Total Capacity
      Installed
      Currently
      After Five Years
      Values rounded to two significant figures
2.3-3, the ETV-verified fuel cells also have the
potential to reduce other emissions, such as CO
and THCs. As discussed in Section 2.3.1, the
environmental and health effects of CO2, NOX,
and other greenhouse gases and pollutants are
significant. Therefore, the benefits of reducing
these emissions also should be significant.
    Also, ETV-verified fuel cells can be and
have been used in CHP installations. Based
on data from the Fuel Cells 2000 database, at
least 39 of the  134 fuel cells currently installed,
or 29%, incorporate heat recovery for purposes
including space heating and cooling and hot
water. Projecting year 2005 CHP installations to
each of the  next five years results in a total of 85
of 224 fuel cells, or 38%, that incorporate heat
recovery. These installations can further reduce
emissions by replacing a conventional heat source,
such as a hot water heater, boiler, or furnace.
These conventional sources can emit significant
quantities of CO2, NOX, and  CO. Because the
test sites did not incorporate heat recovery, the
estimates in Exhibit 2.3-3 do not include these
additional emissions reductions.
Resource Conservation Outcomes
In two of the verification tests, the fuel cells were
powered by biogas—landfill gas in one test and
anaerobic digester gas in the other. These waste
fuels represent a renewable resource and using
them results in the conservation of finite natural
resources in the form of conventional fuels such
as natural gas, oil, and coal. Currently, 10 of the
134 ETV-verified fuel cells operate on anaerobic
digester gas, providing a generating capacity  of
2 MW. After five years, ETV estimates these
numbers would increase to 25 fuel cells with a
capacity of 5 MW. These installations represent
a significant use of a renewable resource. In
addition, they account for most of the CO2
emissions reductions estimated above: 14,000 tons
per year currently and 36,000 tons per year after
five years.25
23 As discussed in Appendix B, based on information from the vendor Web sites, ETV included fuel cells from the two vendors in its count
   even if the technology name was not specified or not identical to that used in the verification reports. The projection, however, does not
   include future installations of one of the technologies. The current and 2005 estimates also exclude short-term demonstration projects.
   Therefore, both the current estimate and future projection are likely to be conservative.
24 Reductions vary based on the source for grid power or thermal supply (hydroelectric, coal, etc.). Reductions here account for CO2
   emissions from the fuel reformer or gas processing units associated with the fuel cells.
25 As discussed in Southern Research Institute (2004b), a small portion of these CO2 reductions are offset by increased emissions of
   methane, another greenhouse gas. The methane increase amounts to less than 1% of the CO2 reduction in terms of greenhouse gas
   potential, or carbon equivalents.
38
                                 Environmental Technology Verification (ETV) Program

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                                                                      2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
Economic and Financial Outcomes
Section 2.3.2 reports the verified efficiencies of
the ETV-tested fuel cell technologies. In general,
these efficiencies compare favorably with those
of separate heat and grid power applications,
particularly when coupled with heat recovery
in CHP applications. In addition, because they
generate and use electricity onsite, fuel cells
avoid losses associated with the transmission of
electricity, which can be in the range of 4.7% to
7.8% (Southern Research Institute, 2001a, 2001b,
2003a, 2004b). In addition to the efficiency
increases, systems that operate on biogas can
result in cost savings for the user by using a  "free"
waste fuel rather than an expensive conventional
fuel. While cost savings can vary depending on
the configuration of the individual installation and
the cost of electricity and fuels, these savings can
be significant (see box at right).

Technology Acceptance and Use Outcomes
The large number of ETV-verified fuel cells
currently installed (see Exhibit 2.3-2) provides
evidence that the technology is becoming
accepted. In addition to the emissions reduction
and resource  conservation benefits discussed
above, another benefit that has contributed to this
acceptance is the technologies' ability to provide
reliable backup power in case of a natural disaster
or other emergency. This benefit is particularly
important for critical emergency services facilities
and facilities  that serve as emergency shelters.
Examples of facilities that have benefited from
ETV-verified fuel cells in this manner include the
following:
    XAMPLES OF UOST SAVINGS FROM
   ETV-VERIFIED FUEL CELLS
   At two colleges in New Jersey:
      "Officials anticipate the plant will cut energy
      costs by over $81,000 annually, recovering the
      college's investment within four years."
      "Combined heat and power operating cost
      savings are estimated to be $259,000 per year."

   At a hospital in Rhode Island:
       "Produces one-third of hospital's electricity
       during peak hours, saving $60,000-$90,000/
       year."
   —Fuel Cells 2000 database (Fuel Cells 2000,2006)
    A high school in New York, where the fuel
    cell "will allow the high school to become
    an emergency shelter during community
    disasters" (Fuel Cells 2000, 2006)
    A high school in Connecticut that serves as a
    regional emergency shelter (Fuel Cells 2000,
    2006; UTC Power, 2006a)
    A government office building in New York,
    where the fuel cell powers the state's regional
    emergency management office (Fuel Cells
    2000,2006)
    A police station in New York City's Central
    Park, a facility routinely affected by power
    shortages prior to installation, where the fuel
    cell provided uninterrupted power during the
    blackout of 2003 (UTC Power, 2006b).
                               ACRONYMS USED IN THIS CASE STUDY:
 CHP            combined heat and power

 CO             carbon monoxide

 CO             carbon dioxide

 DG             distributed generatio

 GHG Center      ETVs Greenhouse Gas Technology Center

 IEEE            Institute of Electrical and Electronics Engineers   PEM

 IPCC            Intergovernmental Panel on Climate Change    THCs
kW     kilowatts

Ibs/kWh  pounds per kilowatt-hour

MW     megawatts

        nitrogen oxides

        phosphoric acid fuel cell

        polymer electrolyte membrane fuel cell

        total hydrocarbons
NOX
PAFC

Environmental Technology Verification (ETV) Program
                                               39

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                                                                 2.4
     MicroturbinelCombined
                           Heat  and  Power
                   (CHP) Technologies
         The ETV Program's Greenhouse
         Gas Technology (GHG) Center,
         operated by Southern Research
         Institute under a cooperative
         agreement with EPA, has verified
the performance of six microturbine systems that
generate electricity at the point of use. Several
of the verified technologies also include heat
recovery systems that capture excess thermal
energy from the system and use it to heat water
and/or spaces. Systems that include this option
are commonly termed combined heat and power
(CHP) systems. Microturbine systems, with or
without heat recovery, can reduce emissions of
carbon dioxide (CO2), methane, and pollutants
including nitrogen oxides (NOX), sulfur dioxide
(SO2), carbon monoxide (CO), particulate matter
(PM), ammonia, and total hydrocarbons (THCs).
CO2 and methane are greenhouse gases linked to
global climate change. CO, SO2, PM, ammonia,
THCs, and the various compounds in the NOX
family, as well as derivatives formed when NOX
reacts in the environment, cause a wide variety of
health and environmental impacts.
   The ETV Program initially prepared this case
study as part of the first volume of ETV Program
Case Studies: Demonstrating Program Outcomes
(U.S. EPA, 2006f). Following publication of
that document, one of the technology vendors
provided important new information on recent
sales. Based on this new information, the ETV
Program has updated the original case study and
is presenting it in this volume.
   Available sales data indicate that a capacity
of 13 megawatts (MW) of ETV-verified
microturbines26 have been installed in CHP
applications in the United States since the
verifications were completed. Based on the
analysis in this case study, the estimated benefits
of these existing installations include the
following:

*  Emissions reductions of up to 36,000 tons per
   year of CO2 and approximately 120 tons per
   year of NOX, with associated climate change,
   environmental, and human health benefits
*  Reduction in emissions of other greenhouse
   gases and pollutants, with additional
   environmental and human health benefits
*  Reduction in natural resource consumption by
   utilizing renewable fuels (such as biogas) or
   by increasing efficiency (and reducing net fuel
   consumption) when well-matched to building
   or facility needs in a properly designed CHP
   application.
   As the capacity of microturbines installed in
CHP applications increases, emission reductions
and other benefits also will increase. In fact, based
on the analysis in this case study and assuming
annual sales continue at the same rate as in 2005,
the ETV Program estimates the total installed
26 This estimate is based on sales from only one vendor and represents between approximately 190 and 220 installations (at 60 to 70 kW per
  installation).
Environmental Technology Verification (ETV) Program
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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
capacity of ETV-verified microturbine/CHP
systems will reach 55 MW in the next five years,27
with the following benefits:

*  Emissions reductions of up to 150,000 tons
    per year  of CO2 and up to 530 tons per year
    of NOX, with associated climate change,
    environmental, and human health benefits
*  Reduction in emissions of other greenhouse
    gases and pollutants, with additional
    environmental and human health benefits
*  Additional reduction in natural resource
    consumption.
    Other benefits of verification include the
development of a well-accepted protocol that
has advanced efforts to standardize protocols
across programs. The Association of State Energy
Research and Technology Transfer Institutions
(ASERTTI), the Department of Energy (DOE),
and state energy offices are adopting this protocol
as a national standard protocol for field testing
microturbines and CHP systems.
   2.4.1  Environmental, Health,
   and Regulatory Background
EPA estimates that, in 2002, the United States
emitted almost 6.4 billion tons of CO2 and nearly
22 million tons of NOX.28 Electricity generation
is the largest single source of CO2 emissions,
accounting for 39% of the total. Electricity
generation also contributes significantly to NOX
emissions, accounting for 21% of the total (U.S.
EPA, 2004e). A variety of other pollutants
also are emitted during electricity generation,
including CO, SO2, PM, ammonia, and THCs.
Each of these  emissions can have significant
environmental and health effects. Conventional
electricity generation also consumes finite natural
resources, with environmental and economic
repercussions.
    CO2 is the primary greenhouse gas emitted
by human activities in the United States. Its
concentration  in the atmosphere has increased
31% since pre-industrial times. As a greenhouse
gas, CO2 contributes to global climate change.
The Intergovernmental Panel on Climate Change
(IPCC) has concluded that global average surface
temperature has risen 0.6 degrees centigrade
in the 20th century, with the 1990s being the
warmest decade on record. Sea level has risen
0.1 to 0.2 meters in the same time. Snow cover
has decreased by about 10% and the extent and
thickness of northern hemisphere sea ice has
decreased significantly (IPCC, 2001a). Climate
changes resulting from emissions of greenhouse
gases, including CO2 and methane, can have
adverse outcomes including the following:

* More frequent or severe heat waves, storms,
   floods, and droughts
* Increased air pollution
* Increased geographic ranges and activity of
   disease-carrying animals, insects, and parasites
* Altered marine ecology
* Displacement of coastal populations
*  Saltwater intrusion into coastal water supplies.
   Each of these outcomes can result in increased
deaths, injuries, and illnesses (U.S. EPA, 1997a).
Many of these impacts, however, depend on
whether rainfall increases or decreases, which
cannot be reliably projected for specific areas.
Scientists currently are unable to  determine which
parts of the United States will become wetter
or drier, but there is likely to be an overall trend
toward increased precipitation and evaporation,
more intense rainstorms, and drier soils (U.S.
EPA, 2000a).
   The various compounds in the NOX family
(including nitrogen dioxide, nitric acid, nitrous
oxide, nitrates, and nitric oxide) and derivatives
formed when NOX reacts in the environment
cause a variety of health and environmental
impacts. These impacts include the following:

* Contributing to the formation of ground-level
   ozone (or smog), which can trigger serious
   respiratory problems
27 This estimate includes the 13 MW that the ETV Program estimates have already been installed. It represents between approximately 790
  and 920 installations total. It is a conservative (low) estimate, as discussed in Appendix C.
28 Values converted from gigagrams as reported in U.S. EPA (2004f).
42
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                                                                    2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
*   Reacting to form nitrate particles, acid
    aerosols, and nitrogen dioxide, which also
    cause respiratory problems
*   Contributing to the formation of acid rain
*   Contributing to nutrient overload that
    deteriorates water quality
*   Contributing to atmospheric particles that
    cause respiratory and other health problems, as
    well as visibility impairment
*   Reacting to form toxic chemicals
*   Contributing to global warming (U.S. EPA,
    1998; U.S. EPA, 2003J).
    Each of the other pollutants emitted during
electricity generation also can have significant
environmental and/or health effects. For example,
SO2 contributes to the formation of acid rain and
can cause a variety of other environmental and
health effects (U.S. EPA, 2006h). THCs and CO
can contribute to ground-level ozone formation,
and CO can be fatal at high concentrations (U.S.
EPA, 2000b; U.S. EPA, 2005n). PM can cause
premature mortality and a variety of respiratory
effects (70 FR 65984). Finally, ammonia can
contribute to PM levels and result in a number of
adverse environmental effects after deposition to
surface water, such as eutrophication and fish kills.
Ammonia also can be fatal  at high concentrations
(U.S.EPA,2004g).
    As discussed in detail in Sections 2.4.2
and 2.4.3, distributed generation technologies
can reduce emissions of CO2, NOX, and other
greenhouse gases and pollutants (e.g., CO,
methane from biogas, SO2, PM, ammonia,
and THCs), as well as conserve finite natural
resources and utilize resources that would
otherwise be wasted (e.g., biogas, landfill gas,
and oilfield flare gas). In recognition of these
benefits, EPA  has established programs such
as the CHP Partnership to  encourage the use
of CHP technologies, including those that
use microturbines. The CHP Partnership is a
voluntary EPA-industry effort designed to foster
cost-effective CHP projects. The goal of the
partnership is  to reduce the environmental impact
of energy generation and build a cooperative
relationship among EPA, the CHP industry, state
and local governments, and other stakeholders to
expand the use of CHP (U.S. EPA, 2005k).
          y installing a CHP system designed to
          meet the thermal and electrical base loads
  of a facility, CHP can increase operational efficiency
  and decrease energy costs, while reducing emissions
  of greenhouse gases that contribute to the risks of
  climate change."—EPA's CHP Partnership Web site
  (U.S. EPA, 2005k)
    In a related effort, EPA and many states are
 developing and using output-based regulations
 for power generators. Output-based regulations
 establish emissions limits on the basis of units
 of emissions per unit of useful power output,
 rather than on the traditional basis of units of
 emissions per unit of fuel input. The traditional,
 input-based approach relies on the use of
 emissions control devices, whereas output-based
 regulations encourage energy efficiency.  Currently
 a number of states, including Connecticut and
 Massachusetts, have developed output-based
 regulations that recognize the energy efficiency
 benefits of CHP projects. Regulated sources
 can use technologies like the ETV-verified
 microturbine/CHP systems as part of their
 emissions control strategy to comply with  these
 regulations. EPA also has developed resources,
 such as Output-BasedRegulations: A Handbook
for Air Regulators (U.S. EPA, 2004f), to  assist in
 developing output-based regulations for power
 generators (U.S. EPA, 20051).
   2.4.2  Technology Description
Electric utilities and others have used large-
and medium-scale gas-fired turbines "to
generate electricity since the 1950s, but recent
developments have enabled  the introduction of
much smaller turbines, known as microturbines"
(U.S. EPA, 2002a). Microturbines are well-
suited to providing electricity at the point of
use because of their small size, flexibility in
connection methods, ability to be arrayed in
parallel to serve larger loads, ability to provide
reliable energy, and low-emissions profile (NREL,
2003). By generating electricity at the point of
use, microturbines reduce the need to generate
electricity from sources such as large electric
utility plants. When coupled with heat recovery
Environmental Technology Verification (ETV) Program
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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
systems that capture excess thermal energy to
heat water and/or spaces, microturbines also
reduce the need to use conventional heating
technologies such as boilers and furnaces, which
emit significant quantities of CO2, NOX, and
CO. When well-matched to building or facility
needs in a properly designed CHP application,
microturbines can increase operational
efficiency and avoid power transmission losses,
thereby reducing overall emissions and net fuel
consumption. Microturbines also can be designed
to operate using biogas from sources including
animal waste, wastewater treatment plants, and
landfills. Biogas is a renewable resource that
otherwise goes unused because it is typically flared
or vented to the atmosphere.
    Because they are relatively new, reliable
performance data are needed on microturbine/
CHP technologies. The ETV Program responded
by verifying the performance of six microturbine
technologies (see Exhibit 2.4-1), four of which
include heat recovery. The verification reports
(Southern Research Institute, 2001a, 2001b,
2001c, 2003a, 2003b, 2004a) can be found at
http://www.epa.gov/etv/verifications/vcenter3-
3.html. Residential, commercial, institutional, and
industrial facilities were used as test sites. One
of the technologies tested operated on biogas
recovered from animal waste.
    During each test, the ETV Program verified
heat and power production, power quality,
and emissions performance. Heat and power
production tests measured electrical power
output and electrical efficiency at selected loads.
For systems with heat recovery, these tests also
measured heat recovery rate, thermal efficiency,
and total system efficiency at selected loads.
At full load under normal operations, electrical
efficiencies ranged from 20.4% to 26.2%. For
systems with heat recovery, thermal efficiencies
at full load and normal operation ranged from
7.2% to 47.2%. For these systems, total system
efficiencies ranged from 33.4% to 71.8%.29 In tests
at less than full load, electrical efficiencies were
lower, but thermal efficiencies were higher. In
tests with enhanced heat recovery (as opposed to
normal operations), thermal and total efficiencies
were higher.
    Power quality tests measured electrical
frequency, voltage output, power factor, and
voltage and current total harmonic distortion.
Verified average voltage outputs ranged  from 215
to 495 volts (for design voltages of 275 to 480
volts). Performance results for the other power
quality parameters are available in the verification
reports, which can be found at the link above.
    Emissions tests measured emissions
concentrations and rates at selected loads. Verified
CO2 emissions rates ranged from 1.34 to 3.90
pounds per kilowatt-hour (Ibs/kWh). Verified
NOX emissions rates ranged from 4.67 x 10 s to
4.48 x  103 Ibs/kWh. The ETV Program also
verified concentrations and emissions rates for
other pollutants and greenhouse gases, including
CO andTHCs, and, for some of the technologies,
methane, sulfate, total recoverable sulfur, total
particulate matter, and ammonia. Three of the
verification reports  also estimated total CO2
reductions compared to emissions generated
by electricity obtained from the grid and heat
obtained from a conventional technology,  either
for the test sites or for hypothetical sites. In two
cases, total NOX reductions were estimated in a
similar manner. These estimates are presented in
One of the ETV-verified microturbine/CHP technologies.
29 Note that the lower end of the range for thermal and total efficiency represents a site where efficiencies under "normal operating
   conditions" were low because of low space heating and dehumidification demand during testing. Excluding this site, the range of thermal
   efficiencies was 21% to 47.2% and the range of total efficiencies was 46.3% to 71.8%.

44                                                     Environmental Technology Verification (ETV) Program

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                                                                        2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
                         ETV-VERIFIED MlCROTURBINE AND CHP TECHNOLOGIES
      Technology Name
      Mariah Energy Corporation Heat
      PlusPower™ System
   Electricity
   Generating
    Capacity
(kilowatts [kW])
       30
 Includes
  Heat
Recovery
for CHP?
   Yes
      Ingersoll-Rand Energy Systems IR
      PowerWorks™ 70 kW Microturbine
      System
      Honeywell Power Systems, Inc. Parallori
      75 kW Turbogenerator
      Honeywell Power Systems, Inc. Parallori
      75 kWTurbogeneratorWith CO
      Emissions Control
      Capstone 30 kW Microturbine System
      Capstone 60 kW Microturbine CHP
      System
                      Yes
                      No
                      Yes
Additional Information
Tested at a 12-unit condominium site that
combines a street-level retail or office space
with basement, and a one- or two-level
residence above.
Tested at a 60,000 square-foot skilled
nursing facility providing care for
approximately 120 residents.
Tested at a 55,000 square-foot university
office building.
Same technology as above, but with
installation of optional CO emissions control
equipment.
Tested system operates on biogas recovered
from animal waste generated at a swine
farm.
Tested at a 57,000 square-foot commercial
supermarket.
       surces: Southern Research Institute, 2001 a, 2001 b, 2001 c, 2003a, 2003b, 2004a.

detail in Appendix C. More detailed performance
data are available in the verification reports for
each of the technologies (Southern Research
Institute, 2001a, 2001b, 2001c, 2003a, 2003b,
2004a).
   2.4.3  Outcomes
Microturbine/CHP systems can be used at
residential, commercial, institutional, and
industrial facilities to provide electricity at
the point of use and reduce the need to use
conventional heating technologies. As discussed
below under "Technology Acceptance and Use
Outcomes," based on data from one vendor, 13
MW of ETV-verified microturbines have been
installed for CHP applications in the United
States since the verifications were completed.
Because this estimate includes sales from only one
vendor, it likely is conservative and represents the
minimum capacity currently installed.
    The ETV Program used these same data
to estimate the capacity of ETV-verified
microturbine/CHP systems that could be installed
in the near future. The vendor reported 8.4 MW
were installed during 2005. ETV extrapolated
                these 2005 sales to each of the next five years
                to estimate that an additional 42 MW could
                be installed during this period. Adding this
                projection to the capacity currently installed,
                results in a total installed capacity after five years
                of 55 MW, as shown in Exhibit 2.4-2. Appendix
                C explains the derivation of the estimates in
                Exhibit 2.4-2 in more detail.30 The ETV Program
                used these capacity estimates to project the
                emissions reduction outcomes shown below.
                           PROJECTED CAPACITY OF ETV-
                           VERIFIED MlCROTURBINElCHP
                       SYSTEMS ESTIMATED TO BE INSTALLED
                      Total Capacity Installed
                      Currently
                      After Five Years
                     Values rounded to two significant figures
                     •^^^^^^^^^^^^^^™
                Emissions Reduction Outcomes
                Emissions reductions from the application of
                microturbine/CHP technology depend on a
                number of factors, including the electricity and
                heating demand of the specific application, the
                microturbine emissions rates, and the emissions
                rates of the conventional source that the
30 As discussed in Appendix C, this is a conservative (low) estimate.
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2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
microturbine replaces, such as an electric utility
power plant or hot water heater. These factors
vary geographically and by specific application.
Given this variation, characterizing these factors
for every potential ETV-verified microturbine/
CHP application is difficult. Therefore, this
analysis uses model facilities developed by
Southern Research Institute for the test sites
to estimate emissions reductions for current
and future installations. Appendix C describes
the model sites and the  method for using the
model facilities to estimate nationwide emissions
reductions for the microturbine capacities shown
in Exhibit 2.4-2.

    Exhibit 2.4-3 shows upper- and lower-
bound estimates of annual CO2 and NOX
reductions generated using this method for the
microturbine capacity currently installed and the
projected capacity after five years. The upper-
bound estimates assume each ETV-verified
microturbine/CHP installation is represented
by the model site that achieves the greatest
reduction for that compound. The lower-
bound estimates assume each ETV-verified
microturbine/CHP installation is represented by
the model site that achieves the lowest reduction
for that compound.
    In addition to the CO2 and NOX reductions
shown in Exhibit 2.4-3, the ETV-verified
microturbine/CHP systems also have the
potential to reduce emissions of other greenhouse
                                              gases, such as methane, and other pollutants,
                                              such as THCs. As discussed in Section 2.4.1, the
                                              environmental and health effects of CO2, NOX,
                                              nd other greenhouse gases and pollutants are
                                              significant. Therefore, the benefits of reducing
                                              these emissions also should  be significant.

                                              Resource Conservation, Economic,
                                              and Financial Outcomes

                                              Section 2.4.2 reports the verified efficiencies of
                                              the ETV-verified microturbine technologies. In
                                              general, these efficiencies compare favorably with
                                              those of separate heat and grid power applications,
                                              particularly when coupled with heat recovery
                                              in CHP applications. In addition, because they
                                              generate and use electricity  onsite, microturbines
                                              avoid losses associated with  the transmission of
                                              electricity, which can be in the range of 4.7%
                                              to 7.8% (Southern Research Institute, 2001a,
                                              2001b, 2003a, 2004b). Also, as  shown in one of
                                              the verification tests, microturbines can be fueled
                                              by biogas, a renewable resource. The application
                                              of the ETV-verified microturbine/CHP  systems
                                              can result in the conservation of finite natural
                                              resources  and potentially result in cost savings for
                                              the user due to efficiency increases and the use of
                                              renewable or waste fuels rather than conventional
                                              fuels. At least one vendor reports significant sales
                                              of their ETV-verified biogas-fueled technology
                                              in the last year (see "Technology Acceptance and
                                              Use Outcomes").
                                                      Annual Reduction (tons per year)
     Total Capacity Installed
                                              Upper Bound

                                                  36,000

                                                  150,000

                                              Lower Bound

                                                  20,000

                                                  83,000
Currently

After Five Years
Currently

After Five Years

Values rounded to two significant figures
31 Reductions vary based on the source for grid power or thermal supply (hydroelectric, coal, etc.).

46                                                     Environmental Technology Verification (ETV) Program

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                                                                       2. AIR AND ENERGY TECHNOLOGY- CASE STUDIES
Technology Acceptance and Use Outcomes
According to recent reports, one verified vendor
has sold 13 MW of ETV-verified microturbines
for CHP applications in the United States
since verification. U.S. sales in 2005 alone were
approximately 8.4 MW (ETV Vendor, 2006). U.S.
sales in 2005 represented approximately half of
the vendor's global sales. Also, 11% of 2005 sales
were for resource recovery applications, many
of which used the ETV-verified biogas-fueled
technology. This vendor projects increasing sales
of ETV-verified microturbines during each of the
next several years (ETV Vendor, 2005). Vendors
also report that ETV verification has increased
awareness of this technology, leading to marketing
opportunities (see quotes at right).

Scientific Advancement Outcomes
Other benefits of verification include the
development of a well-accepted protocol that has
advanced efforts to standardize protocols across
programs. This protocol, the "Generic Field
Testing Protocol for Microturbine and Engine
CHP Applications," was originally developed by
Southern Research Institute for ASERTTI and
was eventually adopted by the GHG Center and
             eople are skeptical of new technology,
             which is why Mariah Energy needed
     believable third-party verification. It may be years
     before we know the impact ETV had on sales, but
     it is already an important factor in discussions with
     our new customers, and ETV has  opened doors
     we didn't anticipate it would. For example, new
     partnering organizations are using ETV data to
     make decisions on investing in our technology.Also,
     new opportunities to conduct field demonstrations
     have occurred, and we've been invited to testify at
     Senate hearings on clean high performance energy
     technology."—Paul Liddy, President and CEO of
     Mariah Energy (U.S. EPA, 2002a)
                e are very proud of our ETV results.
                We cite them all the time, in fact most
     recently in our press release last week."
     —Keith Field, Director of Communications,
     Capstone Turbine Corporation (Field, 2005)
  published as an ETV protocol. The protocol also
  is scheduled to be adopted by ASERTTI, DOE,
  and state energy offices as a national standard
  protocol for field testing.
             Association of State Energy Research and
             Technology Transfer Institutions
             combined heat and power
             carbon monoxide
Ibs/kWh  pounds per kilowatt-hour
        megawatts

        nitrogen oxides

        particulate matter

        sulfur dioxide

        total hydrocarbons
             carbon dioxide

             Department of Energy

 GHG Center   ETVs Greenhouse Gas Technology Center
 IEEE
 IPCC
Institute of Electrical and Electronics Engineers

Intergovernmental Panel on Climate Change
Environmental Technology Verification (ETV) Program
                                                 47

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Water Technology
     Case Studies

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                                                              3J
    Microfiltration  (MF)  and
          Ultrafiltration  (UF)  for
 Removal of Microbiological
                                Contaminants
         The ETV Program's Drinking Water
         Systems (DWS) Center, operated
         by NSF International under a
         cooperative agreement with EPA,
         has verified the performance of
three microfiltration (MF) systems and six
ultrafiltration (UF) systems for removal of
microbiological contaminants. The ETV-verified
systems are easily transportable, making them
ideal for small drinking water systems. The ETV
tests described in this case study verified the
performance of these technologies for the removal
of Cryptosporidium and Cryptosporidium-sized
particles.32 Cryptosporidium is a known infectious
pathogen that causes gastrointestinal infections
and is potentially life threatening for susceptible
populations. To help protect the public from the
health effects of Cryptosporidium, EPA requires
a minimum of 2-log (99%) removal of the
pathogen from filtered drinking water systems
that use surface water sources. EPA also has
finalized the Long Term 2 Enhanced Surface
Water Treatment Rule (LT2ESWTR). This rule
adds Cryptosporidium treatment requirements for
unfiltered drinking water systems and increases
treatment requirements for filtered drinking
water systems with the highest risk levels. As a
result, certain drinking water systems must install
treatment technologies similar to the MF and UF
technologies verified by the ETV Program.
   Based on the analysis in this case study and
25% market penetration, the ETV Program
estimates that:

*  The ETV-verified MF and UF technologies
   would assist up to 550 small drinking water
   systems (out of approximately 2,200 systems)
   in complying with the new standards for
   Cryptosporidium.
*  At these systems, the technologies would
   prevent up to 13,000 cases of cryptosporidiosis
   per year and up to two premature deaths
   per year associated with these cases. The
   technologies also can prevent other negative
   human health effects, including those
   associated with co-occurring contaminants.
*  The technologies would result in economic
   benefits of up to $19 million per year33
   due to the prevention of the above cases of
   cryptosporidiosis.
   Verification has also increased awareness of
the ETV-verified technologies and their benefits
among state regulatory agencies and potential
users. The following benefits have been or can be
realized from the use of the ETV data:
32 The ETV Program also has verified the performance of technologies other than MF and UF for removal of microbiological contaminants.
  This case study specifically covers MF and UF technologies that ETV verified for Cryptosporidium removal. Information on other
  technologies verified for removal of microbiological contaminants can be found at http://www.epa.gov/etv/verifications/'verification-index.
  html.
33 In year 2003 dollars.
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3. WATER TECHNOLOGY CASE STUDIES
*  Twenty-five states reportedly use ETV
    verification data to reduce the frequency
    and/or length of site-specific pilot tests
    for drinking water treatment. The State of
    Utah's drinking water regulations identify the
    ETV Program as a source of performance
    verification data for permitting consideration.
    The State of Massachusetts has proposed
    changes to its regulations whereby, to obtain
    approval of a new drinking water technology
    in Massachusetts, a manufacturer must
    demonstrate  that it has received a favorable
    review from third parties such as ETV or be
    piloted for multiple seasons. EPA's guidance
    manual for membrane filtration under the
    LT2ESWTR cites the ETV test plan as an
    example of a protocol that can be used to meet
    the testing requirements of the rule.
*  Assuming 25% market penetration, up to 550
    systems would use ETV data to reduce pilot
    testing requirements, saving up to $8.3 million
    in pilot testing costs.
*  The reduction in pilot testing length also
    could lead to systems achieving the above
    health benefits sooner than would otherwise
    be possible.
*  Based in part on the results of ETV testing,
    the City of Pittsburgh chose one of the
    verified technologies for full-scale installation,
    demonstrating that the technologies can be
    scaled up for application at large systems. This
    technology saved the City approximately $5
    million compared to conventional treatment,
    and could reduce exposure to Cryptosporidium,
    with associated human health and economic
    benefits.
   3.1.1  Environmental, Health,
   and Regulatory Background
In the United States, more than 14,000 public
water systems serving approximately 180 million
people rely on water sources that are susceptible to
microbial pathogens (U.S. EPA, 2005a), including
Cryptosporidium, Giardia, E. coli, and viruses.
Human and animal fecal matter are common
sources of these pathogens in drinking water, and
all of them can cause a variety of gastrointestinal
illnesses (e.g., diarrhea, vomiting, cramps) (U.S.
EPA, 2003a). Cryptosporidium is of particular
concern because it is resistant to standard drinking
water disinfectants such as chlorine (U.S. EPA,
2005a).
    Cryptosporidiosis, a gastrointestinal illness, is
most often caused by consuming drinking water
contaminated with Cryptosporidium oocysts.
Common symptoms of Cryptosporidiosis in
humans include profuse diarrhea, dehydration,
abdominal cramps, vomiting, and lethargy.
Clinical symptoms, however, vary and can include
renal failure and liver disease. Symptom severity
depends upon immune system status. Patients
with compromised immune systems, such as
children, the elderly, AIDS patients, and cancer
patients undergoing chemotherapy, are especially
susceptible to infection and run a greater risk of
prolonged illness from the infection and possibly
death (U.S. EPA, 2001b).
    EPA has promulgated several regulations
designed to decrease exposure to microorganisms
such as Cryptosporidium. Under the Safe
Drinking Water Act, EPA has established a
Maximum Contaminant Level Goal (MCLG) for
Cryptosporidium of zero oocysts. MCLGs allow
for a margin of safety and are non-enforceable
public  health goals. Current drinking water
regulations require a minimum of 2-log (99%)
removal of Cryptosporidium for all public water
systems that use surface water sources and include
filtration as part of their treatment process (67
FR 1812 and 63 FR 69478). To further reduce
the incidence of disease associated with the
presence of Cryptosporidium (and other pathogenic
microorganisms) in drinking water, EPA finalized
the LT2ESWTR in January of 2006. This rule is
part of the "Microbial-Disinfectants/Disinfection
Byproducts Cluster" rules. Major requirements
of the rule include additional Cryptosporidium
treatment techniques for filtered systems, and
Cryptosporidium inactivation for unfiltered
systems. Under the LT2ESWTR, filtered systems
that are classified in higher risk treatment
categories (or "bins") will be required to reduce
Cryptosporidium levels by  an additional 1-log
to 2.5-log (90% to  99.7%). The LT2ESWTR
also requires 2-log to 3-log (99% to 99.9%)
inactivation of Cryptosporidium by all unfiltered
systems. Approximately 1,900 to 2,900 drinking
52
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                                                                          3. WATER TECHNOLOGY CASE STUDIES
water systems will have to install treatment to
meet the new requirements. Of these systems,
EPA estimates that 76% (or about 1,400 to
2,200) are small systems that serve fewer than
10,000 people each (71 FR 654). Drinking water
systems will begin monitoring programs under the
rule between October 2006 and October 2008,
depending on their size. They generally then will
have three years after completing monitoring
to comply with any additional treatment
requirements (U.S. EPA, 2006a).
   3.1.2  Technology Description
MF and UF technologies work under similar
scientific principles: They both use membranes
as mechanical barriers to remove contaminants.
MF and UF technologies can achieve greater
removals of microbiological contaminants than
conventional filtration technologies (Cadmus
and Pirnie, 2003). They are practical for drinking
water systems of all sizes (U.S. EPA, 2005a).
The ETV-verified systems are all skid-mounted
or easily transportable technologies making
them ideal for small drinking water systems.
Additionally, the filtration systems are largely
automated, thus requiring very little manual
operation (NSF, 2000a, 2000b, 2000c, 2000d,
2000e, 2000f, 2000g, 2000h, 2001,2002,2003a,
2003b).
    The ETV Program has completed 12
verification reports addressing the performance of
nine technologies (three MF technologies and six
UF technologies) for removing Cryptosporidium
and/or Cryptosporidium-sized particles.34 The
verification reports (NSF, 2000a, 2000b, 2000c,
2000d, 2000e, 2000f, 2000g, 2000h, 2001,2002a,
2003a, 2003b) can be found  at http://www.epa.
gov/etv/verifications/vcenter2-6. html, http://www.
epa.gov/etv/verifications/vcenter2-10.html, and
http://www.epa.gov/etv/verifications/vcenter2-
5.html. The testing locations included surface
water supplies in Pennsylvania, Oregon,
Wisconsin, California, and New Hampshire. The
tests took place over periods ranging from 30 to
One of the verified UF technologies

greater than 90 days. Each of the tests measured
water quality results, microbial removal and/or
microbial-sized particle removal, membrane flux
and operation, cleaning efficiency, and membrane
integrity. The tests also tracked operation and
maintenance, usually examining power supply
requirements, chemical consumption, and
operational reliability (NSF, 2000a, 2000b, 2000c,
2000d, 2000e, 2000f, 2000g, 2000h, 2001,2002a,
2003a, 2003b). Exhibit 3.1-1 identifies the ETV-
verified technologies and provides a description of
each.
   ETV testing results indicated that the
technologies were capable of 4.1-log to 6.8-log
removal of Cryptosporidium oocysts and 4.9-log
to 5.8-log removal of Giardia cysts. Protozoa-
size bacteria removals of 4-log were observed. In
addition, ETV-verified UF systems  showed MS-2
bacteriophage removal from 3.3-log to 5.8-log
removal, indicating significant virus removal
capabilities.  Reported system feed or throughput
34 The ETV Program also has verified the performance of technologies other than MF and UF for removal of microbiological contaminants.
  This case study specifically covers MF and UF technologies that ETV verified for Cryptosporidium removal. Information on other
  technologies verified for removal of microbiological contaminants can be found at http://www.epa.gov/etv/verifications/'verification-index.
  html.
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3. WATER TECHNOLOGY CASE STUDIES
               ETV-VERIFIED MF AND UFTECHNOLOGIES FOR MICROBIOLOGICAL REMOVAL
      Technology Name
      Pall Corporation Microfiltration using Microza™
      3-inch Unit, Model 4UFD40004-45
      Pall Corporation WPM-1 Microfiltration System

      US Filter 3MIOC Microfiltration Membrane System
      Aquasource North America Model ASS
      Ultrafiltration System (2)
      F.B. Leopold Company Ultrabar Ultrafiltration
      System Utilizing a Mark III Membrane (60")
      Element
      Hydranautics HYDRAcap8 Ultrafiltration
      Membrane System
      Ionics UF-I-7T Ultrafiltration Membrane system
      Polymem UFI20 S2 Ultrafiltration Membrane
      Model
      ZENON Environmental Systems, Inc.ZEEWEED®
      ZW-500 Ultrafiltration System (3)
                          Description
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^H
 MF Technologies
 A skid-mounted unit with pressure-driven hollow fibers of polyvinylidene
 fluoride and automated controls. Specifically targeted for applications with a
 low flow rate, such as package plants, small commercial operations, schools,
 campgrounds,swimming pools,or small communities (I).
 A skid mounted, stand-alone system with a hollow fiber type MF membrane
 made of polyvinylidene fluoride. Capable of operating in an automatic mode.
 A skid-mounted package plant containing three pressure vessels with hollow
 fiber membrane modules made of polypropylene and automated controls.

 UF Technologies

 A self-contained, skid-mounted system with two hollow fiber membrane
 modules made from a cellulose acetate derivative and automated controls.
 A self-contained, stand-alone system installed in a 20-foot long sea-going
 (watertight) container. Contains two hollow fiber membranes made of
 modified polyethersulfone. Capable of operating in an automatic mode.
 Two hollow fiber membrane modules made of polyethersulfone, mounted
 on a transportable skid constructed of steel. Includes automatic and manual
 controls.
 Seven hollow fiber membrane modules made of polyacrylonitrile, inside an
 aluminum pressure vessel and mounted on a transportable skid. Includes
 automated controls.
 A polyvinyl chloride pressure vessel containing 19 individual polysulfone
 hollow fiber membrane bundles.Tested using a skid-mounted custom
 membrane pilot plant supplied by others.
 A stand-alone system with hollow fiber membranes made of a proprietary
 polymeric compound. Capable of operating in an  automatic mode.
      (I) EPA defines a small system as a system the serves a community of less than 10,000 people.This may or may not agree with
      how the vendors define systems of this size. For clarification, please contact the vendor contact listed on the front page of the
      verification statement posted at http://www.epa.gov/etv/venfications/vcentsr2-6.httnl.

      (2) Verified in May 2000 and September 2000
      (3) Verified in August 2000 and June 2001 for Cryptosporidium removal. Also verified in August 2000 in combination with coagulation
      for removal of Cryptosporidium -sized particles.

      Sources: NSF, 2000a, 2000b, 2000c, 2000d, 2000e, 2000f, 2000g, 2000h, 2001,2002a, 2003a, 2003b.
flow rates ranged from 1 to 60 gallons per minute
(NSF, 2000a, 2000b, 2000c, 2000d, 2000e, 2000f,
2000g, 2000h, 2001,2002a, 2003a, 2003b).
   3.1.3  Outcomes
The most likely market for the ETV-verified
MF and UF technologies includes small drinking
water systems serving less than 10,000 people
that will have to install or modify treatment units
to comply with the new  Cryptosporidium removal
requirements of the LT2ESWTR. Therefore, the
ETV Program used data from the LT2ESWTR
(71 FR 654) to estimate the market for the
technologies. The result  of this analysis, which
is described in more detail in Appendix D, is a
         potential market of approximately 1,400 to 2,200
         systems. It is a conservative (low) estimate of
         the market, because, as shown by the example
         discussed below under "Technology Acceptance
         and Use Outcomes," the technologies also can be
         scaled up for use by larger systems.
             Reports from a technology vendor, discussed
         below under "Technology Acceptance and Use
         Outcomes," provide some evidence of market
         penetration. Because the ETV Program does not
         have access to comprehensive sales data for the
         ETV-verified technologies, the ETV Program
         used two market penetration scenarios,  10% and
         25% of the potential market, to conservatively
         estimate health, economic, and regulatory
         compliance outcomes. Exhibit  3.1-2 lists  the
         number of systems that are projected to apply
54
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                                                                         3. WATER TECHNOLOGY CASE STUDIES
      PROJECTED NUMBER OF SYSTEMS THAT
      WOULD APPLY THE ETV-VER/F/ED MF
             AND UF TECHNOLOGIES
                                 Population
                              Served (number
                                 of people)
                                   220,000
                                   560,000


                                   340,000
                                   860,000
     Values rounded to two significant figures
the ETV-verified technologies based on these
market penetration scenarios. Exhibit 3.1-2
includes upper- and lower-bound estimates of the
number of systems and population served because
the LT2ESWTR included a range of estimates,
based on differing data sources, of the number of
systems serving less than 10,000 people. ETV's
upper-bound estimate corresponds to the high
end of the range presented in the LT2ESWTR
and the lower-bound estimate corresponds to the
low end.

Environmental and Health Outcomes
The human health benefits of removing
Cryptosporidium from drinking water include
the prevention of cases of cryptosporidiosis
and related incidences of premature death.
The ETV Program estimated the number of
cryptosporidiosis cases and related deaths (see
Exhibit 3.1-3) that could be avoided by using the
ETV-verified MF and UF technologies based on
data from the Economic Analysis (EA) for the
LT2ESWTR (U.S. EPA, 2005a) and the market
penetration scenarios described in the previous
section.
    Exhibit 3.1-3 includes upper- and lower-
bound estimates because the EA presents a range
of estimates for the health benefits to be realized
from the LT2ESWTR, based on data from
different sources about the number of systems
and population served.35 Appendix D presents the
assumptions used in this analysis in greater detail.
              ESTIMATED NUMBER OF
          CRYPTOSPORIDIOSIS CASES AND
          ASSOCIATED DEATHS PER YEAR
         PREVENTED BY ETV-VER/F/ED MF
              AND UF TECHNOLOGIES
                  Total Cases       Deaths
     Market        Prevented    Prevented per
     Penetration   perYear(l)      Year (2)
                   Lower Bound
                     1,100            O.I
                     2,700
                   Upper Bound
             	 5,300
             ^^^^^^^H
         25%         13,000            2
     (I)Values rounded to two significant figures
     (2) Values rounded to one significant figure
   In addition to the prevention of
cryptosporidiosis quantified above, the ETV-
verified MF and UF technologies can prevent
other negative human health outcomes associated
with exposure to Cryptosporidium. These include
reduction in risk to sensitive subpopulations and
health risk during outbreaks. The technologies
also can prevent negative human health outcomes
associated with exposure to co-occurring/
emerging pathogens, such as Giardia, E. coli, and
viruses (U.S. EPA, 2005a).
   The estimates in Exhibit 3.1-3 assume
only small systems will apply the ETV-verified
technologies. This assumption is conservative
because, as shown by the example discussed
below under "Technology Acceptance and Use
Outcomes," the technologies can be scaled up
for use by larger systems. If large systems are
considered, the estimated benefits would increase
to approximately 23,000 to 96,000 cases and 5
to 21 deaths prevented per year at 10% market
penetration, with associated economic benefits.

Financial and Economic Outcomes
In addition to personal and societal impacts,
disease prevention also has an economic benefit.
For the LT2ESWTR, EPA quantified the
economic value of the cryptosporidiosis cases
avoided as a range based on differing assumptions
35 These estimates (both upper- and lower-bound) are conservative (low) because they are based on the conservative estimates of the market
  for ETV technologies. In addition, many of the ETV technologies consistently provide Cryptosporidium removal in excess of that required
  by the LT2ESWTR and, thus, could provide even greater benefits.
Environmental Technology Verification (ETV) Program
                                            55

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3. WATER TECHNOLOGY CASE STUDIES
about the value of preventing illness and the
discount rate. The ETV Program estimated the
economic benefits associated with the human
health outcomes shown in Exhibit 3.1-3 based on
the upper-  and lower-bound economic estimates
provided in EPA's EA for the LT2ESWTR (U.S.
EPA, 2005a).
    Exhibit 3.1-4 presents these estimates.36
Appendix D presents the assumptions used in this
analysis in greater detail. Additional economic
benefits could result from the prevention of other
human health outcomes discussed above and
from including predicted impacts for large system
applications.
            ESTIMATED POTENTIAL PILOT
        TESTING SAVINGS FOR ETV-VERIFIED
            MF AND UF TECHNOLOGIES
     Market
     Penetration
         10%
Million dollars per year
Lower         Upper
Bound         Bound
  0.80
  2.0
7.4
     Values rounded to two significant figures
Regulatory Outcomes
States establish drinking water regulations to
ensure that drinking water is safe and meets
applicable drinking water standards. These
rules can govern drinking water system design,
construction, operation, and upkeep, including
testing requirements for alternative/innovative
treatment systems. In some cases, they also
mention or recommend sources of performance
information. For example, section R309-535-
13 of Utah's Safe Drinking Water Act states
that new drinking water treatment processes
         number of treatment processes have
         undergone rigorous testing under the
ETV Program. If a particular treatment process
is a 'verified technology,' it may be accepted in
Utah without further pilot plant testing."—Utah
Department of Environmental Quality, Division of
Drinking Water Web Site (Utah, 2006)
and equipment must be tested before plans can
be approved for their use. It also states that the
ETV Program facilitates deployment by verifying
the performance of new technologies and refers
engineers and manufacturers to ETV's partner,
NSF International, for more information about
testing package treatment processes (Utah, 2005).
The  state's Web site indicates that an ETV-
verified drinking water technology can be accepted
in Utah without further pilot plant testing (see
quote below left). The State of Massachusetts
has proposed changes to its regulations whereby,
to obtain approval of a  new drinking water
technology in Massachusetts, a manufacturer must
demonstrate that it has received a favorable review
from third parties such as ETV or be piloted for
multiple seasons (Massachusetts, 2006). The State
of Washington requires that alternate technologies
for surface water treatment undergo a stand-alone
approval process and indicates that ETV testing
protocols can be used to demonstrate adequate
performance under this process (Washington,
2001). Citations  like these indicate that ETV
testing and data are valued by states and can
provide information that can be used to approve
technology use at the state level.
   State acceptance of verification data can result
in cost savings for drinking water systems that
use the data to reduce the amount of pilot testing
required by some  state regulatory agencies. The
results of a 2003 Association of State Drinking
Water Administrators (ASDWA) survey show
that  a majority of states responding use ETV
verification data to reduce the frequency and/or
length of site-specific pilot tests. The  survey
found that 25 of the 38 states that responded use
ETV data to  reduce pilot testing for surface water
systems and 20 states use ETV data to reduce pilot
testing for ground water systems (ASDWA, 2003).
   Although the survey report does not
specifically mention the applications described
in this case study, to receive removal credit
(and therefore comply with the rule) for a
given technology, the LT2ESWTR requires
that prior testing  be conducted in a manner
that  demonstrates a removal efficiency for
Cryptosporidium commensurate with the treatment
credit awarded to the process. EPA's guidance
36 These estimates are conservative (low) because: (1) they are based on the conservative estimates of the number of cases prevented, and (2)
  they are in year 2003 dollars.

56                                                    Environmental Technology Verification (ETV) Program

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                                                                          3. WATER TECHNOLOGY CASE STUDIES
manual on using membrane filtration for the
LT2ESWTR (U.S. EPA, 2005b) cites the NSF
ETV test plan (NSF, 2005a) as an example of a
protocol that can be used to conduct this testing
economically (see quote at right).
    Thus, it is reasonable to assume that ETV
verification can reduce pilot study costs for
drinking water treatment systems. To estimate
national pilot study cost savings, the ETV
Program assumed a pilot study cost of $20,000
(Adams, 2005). There can be significant
variation in pilot study costs, depending on site-
specific factors, state agency requirements, and
technology type. The ETV Program developed
upper- and lower-bound scenarios with a range of
assumptions about the degree of pilot testing cost
reduction. Appendix D presents the assumptions
used in these scenarios in greater detail.
    Exhibit 3.1-5 presents the estimated pilot
testing cost savings depending on market
penetration scenario.37 In addition to cost savings,
reducing the length of site-specific pilot tests
provides an opportunity for water systems to
comply with the LT2ESWTR requirements more
quickly. Shorter pilot tests could result in systems
achieving health benefits sooner than would
otherwise be possible.
        ESTIMATED PILOT TESTING SAVINGS
           MF AND UF TECHNOLOGIES
                           Million dollars
                       Lower
                       Bound
                         0.29
Upper
Bound
  3.3
Market
Penetration
    10%
   25%
Values rounded to two significant figures
    California has a process under the California
Surface Water Treatment Rule for evaluating
alternative filtration technologies, including MF
and UF. California also has identified several of
the ETV-verified technologies and/or vendors
as having completed demonstrations, primarily
in relation to turbidity. These alternatives are not
intended to be applicable to any future regulations
(i.e., finalization of the LT2ESWTR) until
California officially updates its acceptance process
                        The evaluation of small-scale (as opposed
                        to full-scale) modules during a challenge
               test is permitted under the LT2ESWTR to allow for
               cases in which it may not be feasible or practical
               to test a full-scale module ... the use of a small-
               scale module may be the only economically viable
               alternative .... For the purposes of consistency, it is
               recommended that manufacturers or independent
               testing agencies that opt to subject a product line to
               challenge testing using small-scale modules utilize a
               protocol that has been accepted  by a wide range of
               stakeholders. Such a protocol has been developed
               for use under the National Sanitation Foundation
               (NSF) Environmental Technology Verification  (ETV)
                rogram."—U.S. EPA, 2005b
(California Department of Health Services,
2001a). The results from the ETV demonstrations
could assist in this state program.
    Finally, EPA included the ETV verification
reports for MF and UF technologies in the
rulemaking docket for the LT2ESWTR (EPA-
HQjOW-2002-0039, which can be found at
http://www.regulations.gov). Thus, the ETV
results are part of the scientific and technology
analysis that EPA performed in its decision-
making process for the final rule.

Technology Acceptance  and Use Outcomes
Vendor information indicates that municipalities
are choosing to install the  ETV-verified
technologies. Following completion of ETV
testing at its facility, the Pittsburgh Sewer and
Water Authority (PSWA) chose one of the ETV-
verified technologies for full-scale installation.
The full-scale system treats 20 million gallons per
day, demonstrating that the ETV technologies can
be successfully scaled up for use at large systems.
According to a representative of the PSWA, the
technology was chosen, in part, because of the
results of the ETV testing (see quote on next
page). An evaluation by PSWA and its consultant
showed the technology saved $5 million compared
to conventional treatment technologies (Pall
Corporation, undated). Because it represents a
large system, this  application also could result
in significant health and associated economic
benefits.
37 These estimates are conservative (low) because they are based on the conservative estimates of the market for ETV technologies.

Environmental Technology Verification (ETV) Program                                                    57

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3. WATER TECHNOLOGY CASE STUDIES
         esults of our pilot testing showed that
         the Pall system was not only theoretically
effective, but was able to exceed federally mandated
standards under actual field conditions with water
flowing through our distribution networkThe
system's small footprint and low wastewater rate,
coupled with first-rate design effort, allowed Pall
to submit the most competitive prices.The citizens
of Pittsburgh are really excited  that we will be able
to preserve the beauty of our park while providing
drinking water filtered to the highest levels
available."—Mike Hullihan, Director of Engineering,
Pittsburgh Water and Sewer Authority (Pall
Corporation, 2006)
                                        Scientific Advancement Outcomes
                                        NSF and ETV have recently developed an
                                        updated protocol for testing technologies,
                                        including MF and UF, for removal of
                                        microbiological contaminants (NSF, 2005a).
                                        This protocol incorporates new alternative
                                        testing procedures to address the LT2ESWTR
                                        (Adams, 2006; U.S. EPA, 2004a). EPAs guidance
                                        manual on using membrane filtration for the
                                        LT2ESWTR (U.S. EPA, 2005b) specifically
                                        cites this protocol, as discussed above under
                                        "Regulatory Compliance Outcomes."
 ASDWA
 DWS Center
 EA
Association of State Drinking Water Administrators

ETV's Drinking Water Systems Center

Economic Analysis

 LT2ESWTR     Long Term 2 Enhanced Surface Water
MCLG   maximum contaminant level goal

MF      microfiltration

PSWA   Pittsburgh Sewer and Water Authority

UF      ultrafiltration
58
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                                                                3.2
                        Nanofiltration  for
       Removal of Disinfection
                          Byproduct  (DBP)
                                            Precursors
         The ETV Program's Drinking
         Water Systems (DWS) Center,
         operated by NSF International
         under a cooperative agreement with
         EPA, verified the performance of
a nanofiltration system manufactured by PCI
Membrane Systems Inc. (PCI). The technology is
a transportable, package system designed for small
drinking water systems. It is designed to remove
microbial contaminants and reduce organic
matter that can act as a precursor in the formation
of disinfection byproducts (DBPs). Research
links DBPs, which include total trihalomethane
(TTHM) and the sum of five haloacetic acids
(HAAS), with cancer. Studies also show a possible
association between DBPs and other, non-
cancer human health effects. Under the Stage 1
Disinfectants and Disinfection Byproducts Rule
(DBPR), EPA has set standards for TTHM
and HAAS in drinking water of 80 and 60
micrograms per liter (|ag/L), respectively.  EPA
also has enacted the Stage 2 DBPR to further
reduce disinfection byproducts in drinking water
systems with the highest risk levels. As a  result
of the Stage 1 and 2 DBPRs, certain drinking
water systems must use treatment technologies
similar to the ETV-verified PCI system to control
formation  of DBPs by removing the organic
precursors.
   Based on the analysis in this case study and
25% market penetration, the ETV Program
estimates that:

*  The ETV-verified PCI nanofiltration
   technology would assist 1,200 small drinking
   water systems (out of 4,800 systems) comply
   with EPAs DBP standards.
*  At these systems, the technology could
   prevent up to 20 cases of bladder cancer per
   year.38 The technology also could prevent
   other negative human health effects, including
   developmental and reproductive effects.
*  The technology could result in economic
   benefits of up to $110 million per year39 due
   to the prevention of the above cases of bladder
   cancer.
   Verification has also increased awareness of
the ETV-verified nanofiltration technology and
its benefits among state regulatory agencies and
potential users. The following benefits have been
or can be realized from the availability and use of
the ETV data:

*  Twenty-five states reportedly use ETV
   verification data to reduce the frequency
   and/or length of site-specific pilot tests for
   drinking water treatment and the vendor has
38 In 71 FR 388, EPA acknowledges that causality has not yet been established between chlorinated water and bladder cancer and that the
  actual number of cases attributable to DBPs could be zero. Therefore, the actual number of cases avoided could be as low as zero.
39 In year 2003 dollars. Because causality has not been established, the actual economic value of bladder cancer cases avoided could be as low
  as zero.
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3. WATER TECHNOLOGY CASE STUDIES
    reported this result in several installations of
    this technology. Drinking water regulations
    and guidance in several states identify the
    ETV Program as a source of performance
    verification data and testing protocols.
*  Assuming 25% market penetration, 1,200
    systems would use ETV data to reduce pilot
    testing requirements, saving up to $18 million
    in pilot testing costs.
*  The reduction in pilot testing length also
    could lead to systems achieving the above
    health benefits sooner than would otherwise
    be possible.
*  ETV verification has led to sales of the
    technology by the vendor, potentially
    resulting in reductions in exposure to DBFs
    with human health and associated economic
    benefits.
  3.2.1  Environmental, Health,
  and Regulatory Background
In the United States, more than 48,000 public
water systems serving nearly 260 million people
chemically disinfect their water (U.S. EPA,
2005c). Chemical disinfectants, however, can
react with anthropogenic and naturally occurring
compounds in the water to form DBFs. Since the
discovery of DBFs in 1974, research has shown
that some DBFs, including TTHM and HAAS,
could be associated with increased risks of bladder
and other cancers (71 FR 388; NSF, 2004). While
causality has not been established, EPA believes
that the weight of evidence supports the link
between cancer and exposure to DBFs (71 FR
388).
    In addition, recent studies show a possible
association between exposure to DBFs and
an increased risk of adverse reproductive and
developmental health effects. These health effects
include early-term miscarriage, stillbirth, low
birth weight, and other birth defects. While the
data in these studies are not sufficient to support
a conclusion that exposure  to DBFs causes these
health effects, EPA believes the evidence supports
potential health concerns associated with DBF
exposure (U.S. EPA, 2005c; 71 FR 388).
    To help address the potential health effects
of DBFs, EPA has developed rules to control
DBF formation. These rules, the Stage 1 and
Stage 2 DBF rules, are part of a set of regulations
that address risks from microbial pathogens and
disinfectants/disinfection byproducts. The Stage 1
DBF Rule was promulgated to reduce long-term
exposure to DBFs and cancer health risk. The
Stage 1 DBF Rule set maximum contaminant
levels forTTHMs and HAAS at 80 and 60
|_ig/L, respectively, and required precursor removal
measured as total organic carbon. The Stage 2
DBPR builds on the 1979 Total Trihalomethane
Rule and the 1998 Stage 1  DBPR to decrease
exposure to DBFs. The requirements of the
Stage 2 DBPR apply to water systems that add
a disinfectant other than ultraviolet light (UV)
or deliver water that has been treated with a
disinfectant other than UV. The Stage 2 DBPR
maintains the standards at 80 |-ig/L TTHM and
60 |ag/L HAAS, but requires reporting measured
as locational running annual averages instead of
the Stage 1 running annual average monitoring.
The use of locational running annual averages
targets short-term exposure to DBFs to address
potential reproductive and developmental effects
(71FR388).
    Small drinking water systems, which EPA
defines as those that serve fewer than 10,000
people each, were  required to comply with the
Stage 1 DBPR by January 1,2004 (U.S. EPA,
2001b; 63 FR 69390). Under the Stage 2 DBPR,
small systems must conduct initial evaluations by
July 2010 and begin full compliance monitoring
by October 2013 (U.S. EPA, 2005d). Additionally,
consecutive systems that get their water from
upstream systems  must perform evaluations at the
same time as the parent systems. EPA estimates
that these systems will begin installing treatment
to comply with the Stage 2 DBPR in 2010 (U.S.
EPA, 2005c).
    EPA estimated that nearly 13,000  drinking
water systems would have to install treatment
to comply with the Stage 1 DBPR. Of these
systems, more than 90% (or nearly 12,000) were
small systems (63  FR 69390). In addition, EPA
estimates that more than 2,200 drinking water
systems will have to install treatment processes
to comply with the Stage 2 DBPR. Of these
systems, nearly 80% (or approximately 1,700)
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                                                                        3. WATER TECHNOLOGY CASE STUDIES
are small systems (U.S. EPA, 2005c). The ETV-
verified PCI nanofiltration technology is designed
for use by these small systems (NSF, 2000i, 2004)
and EPA includes nanofiltration among the best
available technologies (BATs) for compliance with
the Stage 1 and Stage 2 DBPRs (63 FR 69390; 71
FR388).
  3.2.2 Technology Description
The ETV Program has verified the performance
of a nanofiltration technology used in package
drinking water treatment systems: the PCI
Membrane Systems Fyne Process Model ROP
1434 with AFC-30 nanofiltration membranes.
Nanofiltration employs a molecular membrane
barrier to remove microbial contaminants
and other small particles, including DBF
precursors such as organic matter. The system
tested was equipped with a membrane module
containing 72 tubular polyamide nanofiltration
membranes connected in series. The PCI system
was originally developed to treat waters with
high concentrations of organic materials. The
technology is designed to both remove microbial
contaminants and reduce organic content that
acts as a precursor in the formation of DBFs. The
system's small footprint, modular construction,
and performance characteristics make it suited
to applications from the smallest to up to
50,000 gallons per day (NSF, 2000i; NSF, 2004;
Howorth, 2006). One innovative characteristic of
the technology is the automated cleaning process
it employs (see quote at right).

   The ETV Program conducted verification
testing for 57 consecutive days at the Barrow
Utilities Electric Cooperative Incorporated in
Barrow, Alaska. Barrow is an Inupiat Eskimo
village that draws  raw water year round from
Isatkoak Reservoir, a surface water source that has
moderate alkalinity, moderate turbidity, and an
elevated organic content. The testing verified that
the nanofiltration membrane effectively removed
organic compounds and particulates from the
source water. The  system reduced raw water total
organic content by over 95%. As a result, the
treatment system was able to reduce the source
water TTHM and HAA5 concentration by 94%
and 98%, respectively, and produced treated water

           unique and innovative feature of the
           PCI nanofiltration system is the use of
  the Fyne Process, an automated foam ball cleaning
  process to remove accumulated organic and
  inorganic foulants from the membrane  surface.
  A valve arrangement allows for a flow direction
  change through the membrane tubes.As the foam
  ball passes down  the membrane tubes, accumulated
  foulants are removed. 'Filter-catchers' (small,
  perforated plates installed in the module inlet and
  outlet lines) retain the foam-balls in the system.
  Cleaning frequency is adjustable and the entire
  process is fully automated." — NSF, 2004
that contained an average of 31 ppb TTHM and
6.2 ppb HAA5. The test skid also removed 47%
to 99% of iron, manganese, calcium, and sulfate
from solution. The testing also confirmed modest
reductions in source water alkalinity (10%) and
total dissolved solids concentration (34.5%) (NSF,
2000i).
    The ETV Program also verified chemical
cleaning performance. A single high pH chemical
cleaning cycle at the end of the two-month
continuous verification test recovered at least
100% of the transmembrane pressure and specific
flux measured at the start of the study. Finally, the
ETV tests examined operation and maintenance
needs, including labor and power requirements
(NSF, 2000i). The verification report (NSF,
2000i) can be found at http://www.epa.gov/etv/
verifications/vcenter2- 7. html.
The PCI Nanofiltration Technology
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3. WATER TECHNOLOGY CASE STUDIES
   3.2.3 Outcomes
The most likely market for the ETV-verified PCI
nanofiltration technology includes small drinking
water systems serving less than 10,000 people
that must install or modify treatment systems to
comply with the Stage 1 and Stage 2 DBPRs.40
The ETV Program used data from the Stage 1
DBPR (63 FR 69390) and the Economic Analysis
(EA) for the Stage 2 DBPR (U.S. EPA, 2005c)
to estimate the market. The result of this analysis,
which is described in more detail in Appendix
E, is a potential market of approximately 4,800
systems. It is a conservative (low) estimate of the
market because it only includes small systems that
were projected to select membranes as of 1998, as
discussed in Appendix E.

    Reports from the technology vendor, discussed
below under "Technology Acceptance and Use
Outcomes," provide some evidence of market
penetration. Because the ETV Program does not
have access to a comprehensive set of sales data
for the PCI nanofiltration technology, the ETV
Program used two market penetration scenarios,
10% and 25% of the potential market, to estimate
health, economic, and regulatory compliance
outcomes. Exhibit 3.2-1 lists the number of
systems that would apply the technology based on
these market penetration scenarios.
                  ome small systems may find
                  nanofiltration cheaper than
    [granular activated carbon] ... if their specific
    geographic locations cause a relatively high
    cost for routine [granular activated carbon]
    shipment."
    —71  FR 388 (page 413)
          PROJECTED NUMBER OF SYSTEMS
           THAT WOULD APPLY THE PCI
           NANOFILTRATION TECHNOLOGY
                              Population Served
                                 (number of
                                   people)
                                    330,000
                                    830,000
     Values rounded to two significant figures
Environmental and Health Outcomes

EPA has determined that reducing DBPs in
drinking water could provide significant health
benefits, including the prevention of bladder
cancer (71 FR 388). The ETV Program estimated
the number of bladder cancer cases (see Exhibit
3.2-2) that could potentially be avoided by using
the ETV-verified PCI nanofiltration technology
based on data in the Stage 1 DBPR (63 FR
69390), the EA for the Stage 2 DBPR (U.S. EPA,
2005c) and the market penetration scenarios
described in the previous section.42 Appendix E
presents the assumptions used in this analysis in
greater detail.
    In addition to the prevention of bladder
cancer quantified above, the PCI nanofiltration
technology could reduce other negative human
health outcomes potentially associated with
exposure to DBPs. These include adverse
reproductive and developmental health effects
and other health effects  (U.S. EPA, 2005c; 71 FR
388).
         ESTIMATED NUMBER OF BLADDER
       CANCER CASES PER YEAR POTENTIALLY
              PREVENTED BY THE PCI
           NANOFILTRATION TECHNOLOGY
      Market Penetration
Number of Cases
   Prevented41
             25%                   20
     Values rounded to two significant figures
40 Although EPA forecasts that few systems would use nanofiltration for compliance with the Stage 2 DBPR (Chen, 2005; U.S. EPA,
  2005c), EPA did list nanofiltration as a BAT for the Stage 2 rule (71 FR 388). EPA also found that some small systems could find
  nanofiltration cheaper than another BAT alternative, granular activated carbon (see quote above). Therefore, nanofiltration is a reasonable
  technology alternative for compliance with the Stage 2 rule.
41 In 71 FR 388, EPA acknowledges that causality has not yet been established between chlorinated water and bladder cancer and that the
  actual number of cases attributable to DBPs could be zero. Therefore, the actual number of cases avoided could be as low as zero.
42 These estimates are conservative (low) because they are based on the conservative estimates of the market for ETV technologies.
  However, because causality has not been established, the actual lower-bound estimate could be as low as zero.
62
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                                                                           3. WATER TECHNOLOGY CASE STUDIES
Financial and Economic Outcomes
In addition to personal and societal impacts,
cancer prevention also has an economic benefit.
For the  Stage 2 DBPR, EPA quantified the
economic value of the bladder cancer cases that
could be avoided as a range based on differing
assumptions about the value of preventing
non-fatal cancer cases and the discount rate.
Based on these assumptions, the ETV  Program
estimated the economic benefits associated with
the potential human health outcomes shown
in Exhibit S.2-2.44 Exhibit 3.2-3 presents the
economic estimates.45 Appendix E presents
the assumptions used in this analysis in greater
detail. Additional economic benefits could result
from the prevention of the other human health
outcomes discussed above. The vendor also
indicates that, because the verified technology is
largely chemical free, that is, it uses no  coagulants,
that it can be cost competitive compared to other
technologies  (Howorth, 2006).
         ESTIMATED POTENTIAL ECONOMIC
           BENEFITS OF BLADDER CANCER
              PREVENTION BY THE PCI
          NANOFILTRATION TECHNOLOGY43
                       Million Dollars per year
                                       Upper
                                       Bound
Market
Penetration
    10%
    25%
Values rounded to two significant figures
Regulatory Compliance Outcomes
States establish drinking water regulations to
ensure that drinking water is safe and meets
applicable drinking water standards. These
rules can govern drinking water system design,
construction, operation, and upkeep, including
testing requirements for alternative/innovative
treatment systems. In some cases, they also
mention or recommend sources of performance
information. For example, section R309-535-
13 of Utah's Safe Drinking Water Act states
that new drinking water treatment processes
and equipment must be tested before plans can
be approved for their use. It also states that
the ETV Program facilitates deployment by
verifying the performance of new technologies
and refers engineers and manufacturers to
ETV's partner, NSF International, for more
information about testing package treatment
processes (Utah, 2005). The state's Web site
indicates that an ETV-verified drinking water
technology can be accepted in Utah without
further pilot plant testing (see quote below). The
State of Massachusetts has proposed changes to
its regulations whereby, to obtain approval of a
new drinking water technology in Massachusetts,
a manufacturer must demonstrate that it has
received a favorable review from third parties
such as ETV or be piloted  for multiple seasons
(Massachusetts, 2006). The State of Washington
requires that alternate technologies for surface
water treatment undergo a  stand-alone approval
process and indicates that ETV testing protocols
can be used to demonstrate adequate performance
under this process (Washington, 2001). Citations
like these indicate that ETV testing  and data are
valued by states and can provide information that
can be used to approve technology use at the state
level.
    State acceptance of verification data can result
in cost savings for drinking water systems that
use the verification data to  reduce the amount
of pilot testing required by some state regulatory
agencies. This outcome is supported by reports
from the vendor that, in the example applications
discussed below under "Technology Acceptance

           number of treatment processes have
           undergone rigorous testing under the
  ETV Program. If a particular treatment process is
  a'verified technology,' it may be accepted in  Utah
  without further pilot plant  testing."
  —Utah Department of Environmental Quality,
  Division of Drinking Water Web Site  (Utah, 2006)
43 Again, because causality has not yet been established, the actual lower-bound estimate could be as low as zero.
44 For the Stage 1 DBPR, EPA used different assumptions about the economic value of avoiding bladder cancer. The ETV Program used
  the Stage 2 economic valuation assumptions because they are based on more recent economic data.
45 These estimates are conservative because they are in year 2003 dollars. For comparison, using the Stage 1 assumptions, the economic
  benefits would be $14 million per year at 10% market penetration and $35 million per year at 25% market penetration in 1998 dollars. In
  either case, however, because causality has not yet been established, the actual lower-bound estimate could be as low as zero.

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3. WATER TECHNOLOGY CASE STUDIES
and Use Outcomes," the cost of pilot testing
was avoided as a result of the data available from
the ETV verification test (NSF, 2004, 2005b).
In addition, the results of a 2003  Association
of State Drinking Water Administrators
(ASDWA) survey indicate that most states
responding use ETV verification data to reduce
the frequency and/or length  of site-specific pilot
tests. The survey found that 25 of the 38 states
that  responded to the survey use  ETV data to
reduce pilot testing for surface water systems and
20 states use ETV data to reduce pilot testing
for ground water systems (ASDWA, 2003).
Although the survey report does  not mention
the applications described in this case study, it is
reasonable to assume that ETV verification can
reduce pilot study costs for DBF  removal.
   To estimate national pilot study cost savings,
the ETV Program assumed a pilot study cost of
$20,000 (Adams, 2005). There can be significant
variation in pilot study costs, depending on site-
specific factors, state agency requirements, and
technology type, the ETV Program developed
upper- and lower-bound scenarios with a range of
assumptions about the degree of pilot testing cost
reduction. Appendix E presents the assumptions
used in these scenarios in greater detail.
   Exhibit 3.2-4 presents the estimated pilot
testing cost savings depending on market
penetration scenario.46 In addition to cost savings,
reducing the length of site-specific pilot tests
provides an opportunity for water systems to
comply with the Stage 2 DBPR requirements
more quickly. Shorter pilot tests could result in
systems achieving potential health benefits sooner
than would otherwise be possible.
                           Million dollars
                      Lower          Upper
Market
Penetration
   10%
     Values rounded to two significant figures
Technology Acceptance and Use Outcomes
Vendor information shows that small drinking
water systems are choosing to install the ETV-
verified nanofiltration technology. PCI has
reported that it has installed at least five new
treatment systems based on the ETV verification
testing. These installations have generated more
than $1 million in sales for the vendor. Thus,
given the cost of participating in the testing, ETV
verification has been a good return on the vendor's
investment (NSF, 2005b). The vendor also reports
that it has installed systems using the Fyne
Process cleaning system in 60 rural communities
in Europe and North America (Howorth, 2006).
Examples of organizations that have chosen to
install the technology include the following:

*  An industrial customer in Alaska chose a six-
    gallon-per-minute system to treat its potable
    water supply (NSF, 2004).
*  The Lower Kushkokwim School District,
    which serves small communities in Alaska
    and covers an area the size of Ohio, installed
    one-gallon-per-minute systems in three of its
    schools (NSF, 2004; Water & Wastes Digest,
    2005).
*  The Conne River Micmac First Nation
    community in the Canadian Province
    of Newfoundland, with a population of
    approximately 700 people, selected a 1.3
    million-liter-per-day (approximately 240
    gallons per minute) system because of savings
    on chemical supplies and sewage disposal costs
    and the high quality of the water produced
    (Infrastructures, 2004).
    Each of these applications could result in
health and economic benefits.
    The National Rural Water Association chose
one of the schools served by the technology as
having the best-tasting water in the nation in its
Great American Water Taste Test, a competition
involving water systems from 48 state rural water
associations (Water & Wastes Digest, 2005). This
outcome suggests that the technology can improve
the aesthetic quality of the water it treats.
46 These estimates are conservative (low) because they are based on the conservative estimates of the market for ETV technologies.

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                                                                                        3. WATER TECHNOLOGY CASE STUDIES
                                    ACRONYMS USED IN THIS CASE STUDY:
 ASDWA       Association of State DrinkingWater Administrators
 BAT           best available technology
 DBPR         Disinfectants and Disinfection Byproducts Rule
 DBP           disinfection byproduct
 DWS Center   ETV's DrinkingWater Systems Center
 EA            Economic Analysis
HAAS
PCI
TTHM
UV
Mg/L
the sum of five haloacetic acids
PCI Membrane Systems Inc.
total trihalomethane
ultraviolet light
micrograms per liter
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                                                                         3.3
            Immunoassay Test   Kits
                 for Atrazine  in  Water
          The ETV Program's Advanced
          Monitoring Systems (AMS)
          Center, operated by Battelle under
          a cooperative agreement with EPA,
          has verified the performance of four
immunoassay test kits for atrazine. These test
kits provide results within hours for atrazine in
various drinking water and environmental water
matrices, allowing the user to quickly identify
and take corrective actions to reduce atrazine
levels or mitigate exposure if detected at levels of
concern. Atrazine is an herbicide that is widely
used in agriculture for corn, sorghum, and other
crops. Because of its frequent usage and concern
about its health and environmental effects, EPA
established a drinking water standard for atrazine
in 1991 of three parts per billion (ppb). EPA
is currently re-evaluating the drinking water
standard to determine if a revision is needed.
As part of the Interim Reregistration Eligibility
Decision (IRED) for atrazine in 2003, EPA
updated the human health risk assessment for
atrazine. The IRED also required additional
atrazine monitoring for certain vulnerable public
drinking water systems and watersheds.
   Based on the analysis in this case study and
25% market penetration, the ETV Program
estimates that:

*  The test kits would be used at 240,000 private
   water wells, 960 community surface water
   systems, and 2,500 watersheds (out of 940,000
   private water wells, 3,900 community water
   systems, and 10,000 watersheds) to provide
   timely information on atrazine levels in water.
   This estimate includes systems and watersheds
   that require additional monitoring under the
   IRED.
*  The information provided by the test kits
   can be used to identify whether mitigation is
   needed to reduce atrazine levels. Ultimately,
   this information can assist in the reduction
   of atrazine exposure, with associated
   environmental and human health benefits.
*  The test kits would reduce monitoring
   costs and save time, since the immunoassay
   analyses used by the verified technologies
   cost approximately five times less than gas
   chromatography/mass spectrometry (GC/MS)
   laboratory analyses and have significantly
   shorter sample turnaround times (hours
   versus days).47 National sampling cost savings
   would be $5,000,000 per year,48 assuming the
   test kits partially replace GC/MS in model
   sampling programs at 960 community surface
   water systems and 2,500 watersheds.
   In addition, the ETV verification results have
been used by state and federal agencies, including
the State of Nebraska  and the National Oceanic
and Atmospheric Administration (NOAA), and
other organizations as a basis for purchasing
ETV-verified atrazine test kits. EPA also is using
the data from the verification studies in deciding
47 This cost savings is most apparent when atrazine is the only contaminant of concern for laboratory analysis.
48 In late 1990s dollars.

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3. WATER TECHNOLOGY CASE STUDIES
whether to withdraw or modify one of the
approved analysis methods used for monitoring
compliance with drinking water regulations.
   3.3.1  Environmental, Health,
   and Regulatory Background
Atrazine is a common herbicide or weed killer
used in the United States. Approximately 76.5
million pounds of atrazine are used annually
in formulations of various products (U.S. EPA,
2003e). These products are widely applied to a
variety of crops, primarily corn and sorghum,
and are also used in nonagricultural (e.g.,
residential) applications. Following application,
atrazine is absorbed by plants or disperses in the
environment through: (1) surface water runoff;
(2) ground water seepage; (3) primary spray
drift settling on adjacent terrestrial and aquatic
habitat; or (4)  air dispersion and precipitation.
Concentrations of atrazine observed in surface
water are seasonal. That is, they increase in the
growing  season. Atrazine is mobile and persistent
in the environment and can be found in surface
water and ground water (U.S. EPA, 2003e).
   As part of its IRED for atrazine, EPA
evaluated atrazine's ecological and environmental
effects. Atrazine is slightly to highly toxic to
fish and slightly to highly toxic to invertebrates,
depending  on  species. Atrazine is slightly toxic
to mammals and birds, and toxic to non-target
plants. Coupling these toxic effects to exposure
scenarios in its IRED, EPA found that atrazine in
the environment could reach levels that are likely
to have an impact on sensitive aquatic species,
particularly during seasonal variations in atrazine
concentrations in ponds, lakes or reservoirs,
streams, and estuaries (U.S. EPA, 2003e).
   In toxicological studies with animals, atrazine
has been shown to disrupt the hypothalamic-
pituitary-gonadal axis, part of the central nervous
system, causing cascading changes to hormone
levels, developmental delays, and reproductive
consequences. These effects are considered
relevant to  humans and are biomarkers of a
neuroendocrine mechanism of toxicity that
is shared by several other structurally-related
chlorinated triazines including atrazine, propazine,
and three chlorinated degradates - G-28279
(des-isopropyl atrazine), and G-30033 (des-ethyl
atrazine), and G-28273 (diaminochlorotriazine)
(U.S.EPA,2003e).
   To help address the potential long-term
human health effects of atrazine in drinking
water, EPA established a maximum contaminant
level (MCL) of 3 ppb under the Safe Drinking
Water Act in 1991. Community water systems
are required to ensure that atrazine is below this
level. Systems that have historically observed
atrazine concentrations above 1 ppb  are required
to monitor quarterly for atrazine under the Safe
Drinking Water Act (U.S. EPA, 2005i). Under
the six-year review of regulated contaminants
required by the Safe Drinking Water Act, EPA
has begun revisiting the MCL for atrazine to
determine if a revision is appropriate. This re-
evaluation will consider the updated human health
risk assessment from the reregistration process for
atrazine discussed below.
   In 2003, EPAs Office of Pesticide Programs
completed an IRED for atrazine following a
detailed review of the potential human health
and ecological risks from the triazine pesticides,
including atrazine, simazine, propazine, and
three chlorinated degradates. The Agency has
since completed a cumulative risk assessment for
the chlorinated triazine class of pesticides and
concluded that, with the mitigation measures in
the individual atrazine and simazine decisions,
cumulative risks are below EPAs Food Quality
Protection Act (FQJPA) regulatory level of
concern. EPAs earlier IRED and Revised IRED
for atrazine are considered final, and the tolerance
reassessment and reregistration eligibility
process for atrazine is complete. As part of the
Agency's determination that atrazine is eligible
for reregistration, EPA and atrazine registrants
developed a Memorandum of Agreement, under
which  the registrants and formulators of atrazine
are required to implement additional steps to
protect human health and the environment (U.S.
EPA, 2003g). These steps include:

•*• A drinking water monitoring program: This
   program is designed to detect levels of
   atrazine and its chlorinated degradates that
   could result in health concerns from short-
   term exposure (i.e., shorter than the exposure
   periods considered in setting the MCL). The
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                                                                          3. WATER TECHNOLOGY CASE STUDIES
   program requires registrants to conduct more
   frequent sampling than that required under
   the Safe Drinking Water Act in community
   water systems served by surface water sources
   that have historically elevated atrazine levels.
   EPA is requiring a minimum of biweekly
   sampling and analysis, with weekly sampling
   during the use season (e.g., when atrazine is
   applied to crops), for a duration  of at least five
   years. These systems and all other community
   water systems also are continuing to perform
   monitoring under the requirements of the Safe
   Drinking Water Act. EPA has additionally
   established a trigger level for all  community
   water systems served by surface water that,
   if exceeded, would require the registrants
   to monitor systems more frequently than
   stipulated in the IRED. Safe Drinking Water
   Act monitoring data will be the  primary
   source for determining if this trigger is met.
   An estimated 130 community water systems
   will require intensive monitoring under this
   program. EPA also requires monitoring for
   rural drinking water wells.
•*•  An ecological monitoring program: This program
   focuses on watersheds known to be vulnerable
   to the impacts of atrazine use. EPA requires
   registrants to perform initial monitoring
   of flowing water bodies (i.e., streams)  in a
   statistical sample of 40 watersheds associated
   with  corn and sorghum production.
   Requirements include identifying multiple
   monitoring sites in the streams and collecting
   samples every four days during the growing
   season for at least two years. Following this
   monitoring, EPA will identify whether further
   monitoring is needed for the 1,172 most
   vulnerable watersheds. Registrants also are
   conducting a program to monitor atrazine
   levels in watersheds associated with sugarcane
   producing areas, and programs are being
   considered for estuaries and static water bodies
   (U.S. EPA, 2003e, 2003f).
   State regulators also have an interest in
monitoring for atrazine. For example, in 2004,
the State of Minnesota conducted sampling at 71
public and private wells to assess atrazine  levels
(Minnesota Department of Agriculture, 2005).
One of the verified immunoassay test kits
Other states, such as Nebraska, regularly conduct
atrazine monitoring in watersheds.
  3.3.2 Technology Description
To help address concerns about the environmental
impacts of atrazine, the ETV Program has verified
four atrazine test kits that measure atrazine
levels in water samples. The verified test kits are
portable, use immunoassay methods, and are
designed to provide near real-time information
(e.g., within hours) about atrazine concentrations
in environmental and drinking water samples.
Conventional laboratory methods use GC/MS
to measure atrazine in water. GC/MS can be
more  costly and time consuming than the test
kits, as discussed in Section 3.3.3. Thus, the
test kits can offer advantages over GC/MS in
terms of time and cost, although they might
not completely substitute for laboratory analysis
when determining compliance with  regulatory
requirements.49
49 For example, EPA's approved methods for measuring atrazine for drinking water compliance monitoring currently include an
  immunoassay method. EPA, however, is considering modifying or withdrawing this method, as discussed in Section 3.3.3.

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3. WATER TECHNOLOGY CASE STUDIES
    All of the verified test kits are based on
colorimetric immunoassay methods, which use
specific antibodies to detect and measure atrazine.
In some cases, structurally similar compounds
also can be detected to varying degrees and be
quantified as atrazine as a result of cross-reactivity.
Three of the verified test kits provide quantitative
results, while the fourth is  a qualitative method
(i.e., the technology identifies if the sample
exceeds the MCL, but does not provide a
quantitative measurement) (Battelle, 2004b,
2004c, 2004d, 2004e). Exhibit 3.3-1 identifies the
ETV-verified technologies and indicates the type
of result each provides.
         ETV-VERIFIED IMMUNOASSAY TEST
           KITS FOR ATRAZINE IN WATER
     Technology
     Abraxis LLC Atrazine ELISA Kit
     Beacon Analytical Systems, Inc.
     Atrazine Tube Kit
     Silver Lake Research Corporation
     Watersafe® Pesticide Kit
Type of Result
  Quantitative
  Quantitative

   Qualitative
     Strategic Diagnostics, Inc.             Quantitative
     RaPID Assay® Kit
     Sources: Battelle 2004b, 2004c, 2004d, 2004e.

    The verification tests were conducted in
September 2003 on surface water samples
collected in South Carolina, ground water
samples from an aquifer on the Missouri River,
and chlorinated drinking water samples from a
Battelle laboratory in Duxbury, Massachusetts.
A staff member from the Texas Commission on
Environmental Quality (Texas CEQ) analyzed
the samples using the immunoassay test kits at the
Battelle laboratory. EPA's Office  of Prevention,
Pesticides, and Toxic  Substances  analyzed the
split samples by GC/MS according to modified
EPA Method 525.2 at the EPA Environmental
Chemistry Laboratory. The AMS Center also
collaborated with NOAA and the University of
Missouri-Rolla, who  collected the environmental
samples (Battelle, 2004b, 2004c, 2004d, 2004e).
    The ETV Program evaluated the test kits
for the following parameters: accuracy, linearity,
matrix interference, rate of false positives/
negatives, precision, method detection limit,
cross-reactivity, and sample throughput. Various
matrices were analyzed, including performance
test samples using ASTM water and the
environmental samples discussed above. Results
from the GC/MS reference analyses performed
by OPPTS were used, in part, to define the
occurrence of false positives and false negatives
for the test kits.  Control samples, analyzed in
accordance with vendor instructions using a
sample supplied by the vendor, were used to verify
that the test kits were calibrated properly and
reading within defined control limits. Exhibit
3.3-2 summarizes some of the performance
data for the verified technologies. Because the
ETV Program does not compare technologies,
the performance results shown in Exhibit 3.3-2
do not identify the vendor associated with each
result and are not in the same order as the list of
technologies  in Exhibit 3.3-1. Also, additional
information on the quality assurance and quality
control procedures employed during testing can be
found in the verification reports (Battelle, 2004b,
2004c, 2004d, 2004e), which are posted at http://
www. epa.gov/etv/veriftcations/vcenterl -28. html.
    Accuracy, precision, and linearity were
determined for the three test kits that provide
quantitative results. The ETV Program verified
that the average relative accuracy for the monitors,
calculated as  percent recovery, ranged from 82%
to 171% depending on the matrix analyzed.
A result of 100% indicates perfect accuracy
compared to  the tested atrazine concentration.
The concentrations of atrazine as measured by
several of the test kits were found to be biased
high. The precision, as relative  standard deviation,
ranged from 0.9% to 51.1%. A result of 0%
indicates perfect precision. The ETV Program
used linear regression to correlate the test kits over
the range of atrazine concentrations tested (0.1
to 5 ppb). The slope values ranged from 0.81 to
1.23; the intercept values ranged from -0.025 to
0.26 ppb; and the correlation coefficient (r)  values
ranged from 0.9575 to 0.9950.50 The frequency
50 Slope and intercept are measures of the relationship between test kit response and the standard or reference method value. The degree to
   which the slope deviates from a value of 1 and the intercept deviates from zero are indicators of the test kit's accuracy or comparability to
   the reference method. The correlation coefficient r is a measure of how well observed data fit a linear relationship. Values of r range from
   0 to 1, with values closest to 1 indicating a better fit. Thus, an r value near 1 indicates a high linearity over the range of concentrations
   tested and high comparability to the standard test method.

70                                                      Environmental Technology Verification (ETV) Program

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                                                                               3. WATER TECHNOLOGY CASE STUDIES
          PERFORMANCE OF ETV-VERIFIED IMMUNOASSAYTEST KITS FORATRAZINE IN WATER* '
                                                                             Linearity
                                                                               (slope,         Sample
                                                                          intercept, r) (3) throughput (4)
Technology
A
Accuracy
(percent
recovery) (2)
PT:96to 151%
Env: 102 to 156%
Precision
(relative
standard
deviation)
PT:0.9to5l.l%
Env: 2.6 to 1 6.7%
Rate of false
positives
4 of 38
(11%)
Rate
of false
negatives
none
PT:l02to 127%
Env: 100 to 140%
PT:82to 133%
Env: 83 to 171%
PT: 18 of 21
Env: 3 1 of 36
PT: 6.9 to 24.1%
Env: 3.5 to 15.2%
PT: 5.0 to 25.4%
Env: 3.9 to 22.8%
PT: 7 of 7
Env: 9 of 12
4 of 38
(11%)
6 of 38
(16%)
8 of 56
(14%)
none
none
none
                                                                          Slope: 0.93
                                                                          Intercept: 0.26
                                                                          r: 0.9950
                                                                          Slope: 1.23
                                                                          Intercept: -0.025
                                                                          r: 0.9937
                                                                                     50-60 samples in
                                                                                     1.5 hours
                                                                                     (27-40 per hour)
                                                                                     50 samples in
                                                                                     I hour
                                                                          Slope: 0.81
                                                                          Intercept: 0.24
                                                                          r: 0.9575
                                                                          Not evaluated
                                                                                     30 samples ir
                                                                                     I hour
                                                                                     0 samples in
                                                                                     !/2 hour
                                                                                     (20 per hour)
(I) The technology used by Vendor D is a qualitative method (i.e., the technology identifies if the sample exceeds the MCL, but does
not provide a quantitative measurement). In this case,"accuracy" refers to the number of accurate results out of the total number
of tests, and "precision" is the number of consistent sets of replicate sample results out of total number of sets.
(2) PT = Performance test samples; Env = Environmental samples (overall range for all environmental samples)
(3) Linearity was assessed using PT samples
(4) Sample throughput includes calibration standards, QC samples, and test samples
Sources: Battelle, 2004b, 2004c, 2004d, 2004e.
of false positive and false negative readings was
measured for all four of the test kits. For the three
quantitative technologies, between 4 and 6 of 38
samples evaluated were false positive readings.
That is, the test kit identified that atrazine was
present, but the actual atrazine concentration was
less than the lowest calibration standard of 0.1
ppb. For the fourth technology, 8 of 56 samples
evaluated were false positive readings compared to
a 3 ppb threshold level. No false negative readings
were identified for any of the  four technologies
(Battelle, 2004b, 2004c, 2004d, 2004e).
   The costs of the technologies were reported
by the vendors. For the kits providing quantitative
measurements, costs ranged from $230 for a set
of 30 tubes to $510 for a set of 100 tubes. For
the kit providing qualitative measurements, costs
were $60 for a set of 10 packets, with each packet
containing a test vial, pipette, and single test strip.
The quantitative kits require additional  equipment
such as pipettes and a photometer.
                                                    3.3.3  Outcomes
                                                  The market for the ETV-verified atrazine test
                                                  kits includes users that monitor community water
                                                  systems, private water wells, and watersheds. The
                                                  ETV Program developed the following estimates
                                                  of the market for each category:

                                                  •*•   Community Water Systems: Based on data
                                                      from the IRED (U.S. EPA, 2003e) and U.S.
                                                      EPA (2005m), the ETV program estimates
                                                      that approximately 3,900 community surface
                                                      water systems are located in atrazine use
                                                      areas.52 Because systems using surface water
                                                      are those most likely to be affected by atrazine
                                                      (U.S. EPA, 2003e), the ETV Program limited
                                                      its estimate of the potential market in this
                                                      category to surface water systems.
                                                  *   Private Water Wells: Based on data from several
                                                      sources (U.S. Department of Agriculture,
                                                      2004; InfoPlease, 2000; U.S. Census Bureau,
                                                      1990), the ETV Program estimates that
51 Because the ETV Program does not compare technologies, the performance results shown in Exhibit 3.3-2 do not identify the vendor
  associated with each result and are not in the same order as the list of technologies in Exhibit 3.3-1.
52 U.S. EPA (2005m) reported there are 11,574 community surface water systems in the United States. The IRED (U.S. EPA, 2003e)
  conducted exposure assessments for 33% of these systems and reported that this 33% represents 99% of atrazine use. Thus, the total
  number of community surface water systems in atrazine use areas would be 11,574 x 0.33 / 0.99 = approximately 3,900.

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3. WATER TECHNOLOGY CASE STUDIES
    approximately 940,000 private wells are
    present in atrazine use areas.53 This number
    represents the potential market of private wells
    that could apply the ETV-verified test kits.
*  Watersheds: As part of the IRED, EPA
    identified approximately 10,000 watersheds
    where atrazine is used for corn and sorghum
    production (U.S. EPA, 2003f). This number
    represents the potential market of watersheds
    that could apply the ETV-verified test kits.
    Reports from state regulators and vendors,
discussed below under "Technology Acceptance
and Use Outcomes," provide some evidence of
market penetration. Because the ETV Program
does not have access to a  comprehensive set of
sales data for the ETV-verified test kits, ETV
used two market penetration scenarios, 10%
and 25% of the potential  market, to estimate
the number of locations that would adopt the
technologies, as shown in Exhibit 3.3-3.

Pollutant  Reduction, Environmental,
and Human Health Outcomes
As discussed in Section 3.3.1, atrazine is likely
to have an adverse impact on sensitive aquatic
species, has adverse effects on animals,  and has
potential long-term human health effects. Use
of ETV-verified test kits  for watersheds, well
water, or small drinking water systems can lead
to the timely identification of atrazine levels. If
atrazine is  detected at levels  of concern, users
can take corrective actions to reduce atrazine
levels or mitigate exposure. Such actions could
include reducing application rates in affected
                      areas or encouraging improvements in agricultural
                      practices. Thus, use of the verified technologies
                      can result in reduction of atrazine in water, with
                      health and environmental benefits.

                      Financial and Economic Outcomes
                      The verified technologies can be used for
                      screening a large number of samples, resulting
                      in savings of time and money over conventional
                      techniques. As part of its ground water
                      monitoring program for  herbicides and pesticides
                      including atrazine, Texas CEQ_uses immunoassay
                      test kits with laboratory confirmation, such as
                      by GC/MS. Costs for samples analyzed during
                      the late  1990s  using the immunoassay methods
                      (average of $37 per sample for 162 samples)
                      were substantially less than costs for laboratory
                      methods (average of $211 per sample for 72
                      samples). Advantages of the test kits cited by
                      Texas CEQ_staff include lower cost, faster
                      turnaround, increased portability, and lower
                      detection limits over laboratory methods (Musick
                      et al., 2000). This cost savings is most apparent
                      when atrazine  is the only contaminant of concern
                      for laboratory  analysis.
                         To estimate cost savings from the use of
                      the ETV-verified test kits, the ETV Program
                      assumed they could be used at each of the
                      community water systems and watersheds
                      shown in Exhibit 3.3-3 in a program of frequent
                      sampling designed for early detection of elevated
                      atrazine concentrations. ETV assumed this model
                      sampling program would undertake biweekly
                      sampling during a six-month growing season,
                      for a total of 12 samples per year. Verified test
     Market
     Penetration
Community Surface
  Water Systems
Water-
 sheds
  1,000
 2,500
Private Wells
    94,000
   240,000
        ues rounded to two significant figures
53 To estimate the ptivate well matket, the ETV Program used data from the 1990 Census to identify the number of drinking water wells
   in each state, 2004 data from U.S. Department of Agriculture to identify the acreage of corn and sorghum in each state, and data from
   InfoPlease (2000) to identify the land area of each state. As a simplifying assumption, only corn and sorghum (the principal uses of
   atrazine) were evaluated and the ETV Program assumed 100% of these crops were treated with atrazine. The ETV Program assumed the
   wells were evenly dispersed in the state, such that the percent of acreage used for these two crops (i.e., as a percentage of total land area)
   was equal to the percent of wells potentially affected by atrazine. The numbers of such wells in each state were summed to obtain the
   nationwide estimate. This estimate is conservative because private wells tend to be clustered in agricultural use areas rather than dispersed
   evenly throughout the state as assumed in the calculation.

72                                                      Environmental Technology Verification (ETV) Program

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                                                                          3. WATER TECHNOLOGY CASE STUDIES
kits would replace GC/MS for all samples
except those showing an elevated concentration,
which would require GC/MS confirmation.
Assuming 25% of the samples required GC/MS
confirmation and using the average costs reported
in Musick et al. (2000), a program using the
verified test kits would save approximately $1,500
per year at each community water system and
watershed.54 Exhibit 3.3-4 shows the estimated
national annual sampling cost savings. These
estimates exclude private wells, because these
are less likely to be tested using conventional
laboratory analysis.ss
   The verified technologies also provide a time-
effective method of sample analysis. The ETV
Program evaluated the verified technologies in
terms of sample throughput for a given batch as
identified in Exhibit 3.3-2. All the test kits can
process multiple samples in approximately one
hour, as opposed to one to two samples per hour
using GC/MS. Throughput time is decreased
over GC/MS techniques because, unlike GC/MS,
multiple samples can be analyzed concurrently
using immunoassay technologies.

Regulatory Outcomes
EPA currently is considering whether to continue
to allow the use of an immunoassay method (the
"Syngenta method") to comply with drinking
water monitoring requirements. EPA originally
        ESTIMATED ANNUAL SAMPLING COST
           SAVINGS FROM ETV-VERIFIED
           IMMUNOASSAY TEST KITS FOR
              ATRAZINE IN WATER (I)
                              Cost Savings
                             (million dollars)
     Values in late 1990s dollars, rounded to two significant
     figures
     (I) Assumes tests kits would be used in a model sampling
     program, as described in the text, at 390 and 960
     community surface water systems and 1,000 to 2,500
     watersheds, respectively.
approved the Syngenta method in 2002. In 2004,
EPA proposed to withdraw the method due to
concerns regarding interferences with chlorine
and chlorine dioxide, which are sometimes added
to drinking water in treatment plants (69 FR
18116). Subsequently, EPA published a Notice of
Data Availability seeking further comments on
whether to modify or withdraw the method, given
additional data. The notice included the four ETV
verification reports as part of the information to
be considered in this decision (70 FR 7909). The
ETV data will contribute to EPA's future decision
to modify or withdraw the Syngenta method for
use in drinking water compliance measurements.

   Given the pending decision, it is uncertain
whether the ETV-verified test kits will be
applicable for compliance monitoring purposes
under the Safe Drinking Water Act. They
could, however, provide a quick and cost-
effective screening method for atrazine levels,
with subsequent laboratory confirmation. As
discussed in Section 3.3.1, EPA has developed a
Memorandum of Agreement with the atrazine
registrants and formulators that requires
the registrants to conduct water monitoring
programs to identify elevated levels of atrazine in
community surface water systems with historically
elevated atrazine levels and watersheds that
are known to be vulnerable to the impacts of
atrazine use. These monitoring programs apply
to 130 community water systems and a statistical
sample of 40 watersheds, with possible future
extension to up to 1,172 vulnerable watersheds.
These monitoring programs are currently using
immunoassay test kit methods followed by
laboratory confirmation (e.g., GC/MS methods).
ETV-verified technologies could assist in this
program.

Scientific Advancement Outcomes
ETV also stimulates technology innovation. One
of the participating vendors asserts that the ETV
Program provides an incentive for companies,
including small companies, to improve or develop
environmental technologies (see quote next page).
54 A program using GC/MS would cost 12 x $211 = approximately $2,500 per year. A program using the verified test kits would cost 12 x
  $37 + 0.25 x 12 x $211 = approximately $1,000 per year.
55 These estimates are conservative because they exclude potential savings for private wells and they are in late 1990s dollars.

Environmental Technology Verification (ETV) Program                                                    73

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3. WATER TECHNOLOGY CASE STUDIES
            ithout a program like ETV to get a
            company over the 'valley of death,'
an innovator company like Silver Lake Research
would not even know where to begin to market
their technologies in EPA-regulated markets. It is
not just a question of having the ability to validate a
technology to get them over that state, it is the fact
that, without knowing ETV exists, companies like
[Silver Lake Research] would not begin to develop
new technologies for environmental markets
because they would not see the means to get them
to the marketplace ....There is a hidden value in
having the program in place and having stakeholders
and users ask for the technologies to be evaluated.
Another advantage is the opportunity to have
technologies looked at by EPA during the early
stages to enable small companies to improve or
further develop new technologies. It is possible that
a lot more of these types of technologies would
come out of nowhere if vendors knew that there
was a stakeholders path to some type of validation."
—Mark Geisberg, Director of Research and
Development, Silver Lake Research Corporation
(U.S. EPA, 2004a)
Technology Acceptance and Use Outcomes
State, federal, and other organizations are actively
using the verified atrazine test kits. For example,
NOAA's National Ocean Service's Center for
Coastal Environmental Health and Biomolecular
Research Center in Charleston, South Carolina,
uses the kits for monitoring water quality in
coastal ponds. NOAA found ETV's qualiry-
assurance/quality-control program, as well as
timely posting of results on the EPA Web site,
as extremely important in deciding to use these
technologies (U.S. EPA, 2004a). The Nebraska
Department of Environmental Quality also began
using two of the ETV-verified test kits in summer
2004 for surface water/watershed monitoring.
Nebraska used the results obtained from the ETV
verifications in deciding to select the test kits
(Link, 2005). Texas CEQjuses the ETV-verified
test kits for their ground water monitoring
program (Musick et al., 2000). Based in part
on the ETV results, a study (Graziano et al.,
2006) sponsored by the American Water Works
Association also chose one of the verified test kits
for use in weekly sampling of 47 drinking water
facilities over a seven month period (Graziano et
al., 2006; Rubio, 2006).
                                ACRONYMS USED IN THIS CASE STUDY:
 AMS Center    ETV's Advanced Monitoring Systems Center

 GC/MS        gas chromatography/mass spectrometry

 IRED          Interim Reregistration Eligibility Decision

 MCL          maximum contaminant level
       ppb

       Texas CEQ
National Oceanic and Atmospheric
Administration
parts per billion

Texas Commission on Environmental
Quality
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                                                               3.4
                            Ultraviolet  (UV)
                             Disinfection  for
         Secondary Wastewater
  Effluent  and  Water  Reuse
         The ETV Program's Water Quality
         Protection (WQP) Center,
         operated by NSF International
         under a cooperative agreement with
         EPA, verified the performance of
three ultraviolet (UV) disinfection systems for
secondary wastewater effluent and water reuse
applications. These technologies can be used
in place of chemical disinfection to inactivate
or destroy infectious organisms in wastewater
treatment plant effluent prior to release or
reuse. Ultimately, these technologies can help
to prevent infectious organisms, such as E. coli
and enterococci, from contaminating beaches,
drinking water supplies, and shellfish beds,
potentially reducing outbreaks of disease and
beach closings. Wastewater treatment facilities
can use these technologies to install or upgrade
disinfection systems, allowing them to comply
with discharge standards, including those under
the Total Maximum Daily Load (TMDL)
program and the recently established health-
based federal bacteria standards for states and
territories bordering Great Lakes or ocean waters.
As water demands grow, these technologies could
become an increasingly important element of
private, state, and/or regional water reuse projects,
providing a way to disinfect wastewater to meet
state reuse regulations or guidelines. Water reuse
is particularly important in areas where water
resources are scarce and/or where water demands
are high, providing these areas with a dependable,
locally controlled water supply that can be used
for irrigation, industrial cooling, vehicle washing,
and dust control.
  Based on the analysis in this case study and
25% market penetration, the ETV Program
estimates that:

* The ETV-verified UV disinfection
  technologies would be installed at 77
  wastewater treatment facilities (out of 309
  facilities) that, based on the results of the 2000
  Clean Watersheds Needs Survey, plan to add
  UV disinfection, replace existing disinfection
  technology with UV, or expand their UV
  disinfection capacity.
* The technologies would assist 23 wastewater
  treatment facilities (out of 90 facilities) in
  complying with EPA's new water quality
  standards for coastal and Great Lakes
  recreation waters. They also could assist
  facilities that discharge to any of the 8,690
  river segments, lakes, and estuaries listed as
  impaired by pathogens in complying with
  TMDL requirements. Installation at these
  facilities, as well as the facilities above, would
  have human health and environmental benefits
  including prevention of disease and reduced
  restrictions on the use of natural resources.
* The technologies would enable water reuse
  at 29 facilities in Florida and California
  (out of 114 facilities), resulting in the
Environmental Technology Verification (ETV) Program
                                 75

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3. WATER TECHNOLOGY CASE STUDIES
    capacity to recycle 140 million gallons per
    day (MGD) of water. The resulting reuse
    would have environmental benefits including
    resource conservation, pollution reduction,
    and environmental restoration. In addition
    to avoiding alternative water supply and
    waste discharge costs, reuse would realize
    economic benefits associated with avoiding
    environmental impacts.
*  The technologies would replace chemical
    disinfection at many of the facilities above,
    avoiding the adverse health effects potentially
    associated with disinfection chemicals,
    eliminating the need to manage hazardous
    chemicals, and potentially reducing operating
    costs.
    In addition, the ETV protocol for validating
UV technologies has been acknowledged by
the State of California as meeting a minimum
requirement for acceptance of a technology under
the state's regulations for UV disinfection, because
the protocol touches on the major points of the
National Water Research Institute/American
Water Works Association Research  Foundation
UV Disinfection Guidelines (California
Department of Health Services, 2001b). This
provides an advantage for ETV-verified vendors
in gaining acceptance from the state regulatory
agency and in marketing their technology in
California. It also represents the first step in
national acceptance of a standardized protocol,
with benefits for vendors and regulatory agencies
alike.
   3.4.1  Environmental, Health,
   and Regulatory Background
Wastewater effluents can contain an array of
pathogenic organisms that can cause a variety of
diseases in humans, as shown in Exhibit 3.4-1.
Pathogen-containing discharges  also can limit the
public's ability to use valuable natural resources,
such as beaches, lakes, and rivers. For example,
in 2005, more than 1,100 U.S. beaches, 28% of
those monitored, were posted with warnings or
                               Disease Caused
                       Bacteria
                            Gastroenteritis
Escherichia coli
(enterotoxigenic)
Leptospira (spp.)
     Salmonella typhi
Salmonella (=2,100
serotypes)
Shigella (4 spp.)
                            Shigellosis (bacillary
                            dysentery)
                            Cholera
                       Protozoa
                            Balantidiasis
                            Cryptosporidiosis
                            Amebiasis (amoebic
                            dysentery)
                            Giardiasis
                      Helminths
                      ^^^^^^^^^^^^^H
                            Ascariasis
                            Taeniasis
                            Trichuriasis
                        Viruses
Vibrio cholerae
Balantidium coli
Cryptosporidium parvum
Entamoeba histolytica
Ascaris lumbricoides
T. solium
Trichuris trichiura
     Enteroviruses (72 types, e.g.,  Gastroenteritis, heart
     polio, echo, and coxsackie    anomalies, meningitis
     viruses
     Hepatitis A virus
     Norwalk agent
     Rotavirus
                       Infectious hepatitis
                       Gastroenteritis
                       Gastroenteritis
     Source: U.S. EPA, 1999a (adapted from Crites and
     Tchobanoglous, 1998).
closed for at least one day because the water was
contaminated with pathogenic organisms (U.S.
EPA, 2006c).
    To protect the public from the health effects
of pathogenic organisms in water, EPA sets
water quality criteria under the Clean Water Act.
States are required to adopt standards at least as
stringent as these criteria and can adopt more
stringent standards. Recently, EPA established
health-based federal bacteria standards for
a number of states and territories bordering
the Great Lakes or ocean waters. These more
stringent standards apply in areas that have not
56 The new standards set limits for E. coli and enterococci because, although these organisms generally do not cause illness themselves, they
   are indicator organisms that help identify where disease-causing microbes could be present. Indicator organisms are used as the water
   quality criteria because most disease-causing microbes exist in very small amounts and are difficult and expensive to find in water samples
   (U.S. EPA,2004d).
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                                                                           3. WATER TECHNOLOGY CASE STUDIES
yet adopted standards in accordance with the
Beaches Environmental Assessment and Coastal
Health Act of 2000 (U.S. EPA, 2004c). These
criteria limit the geometric mean for enterococci
in marine coastal recreation waters to 35 colonies
per 100 milliliters (35/100 mL) and add four
different single sample maximums, which vary
based on how the water body is used. For fresh
coastal recreation waters, the criteria limit the
geometric mean for E. coli to 126/100 mL and
for enterococci to 33/100 mL, also with different
single sample maximums based on intensity of use
(69 FR 67218).56
   Also, under section 303(d) of the Clean Water
Act, states are required to identify impaired waters
that do not meet water quality standards even
after point sources of pollution have installed the
minimum required levels of pollution control
technology. There are 8,690 river segments, lakes,
or estuaries listed as impaired by pathogens,
accounting for  almost 15% of the total number
of impaired waters and representing the second
most frequent general cause of impairment
(after metals) (U.S. EPA, 2006d). States must set
priorities for these impaired waters  and develop
TMDLs that specify the maximum amount of
a pollutant that a waterbody can receive. Under
the TMDLs, states allocate pollutant loadings
among point and non-point pollutant sources
(U.S. EPA, 2006e). To ensure the nation's waters
meet criteria like those established under the
TMDL program or the federal bacteria criteria,
wastewater treatment plants and other facilities
that discharge to our nation's water bodies could
be required, through their National Pollutant
Discharge  Elimination System permits, to modify
or install treatment systems capable of disinfecting
their effluent.
   The removal or destruction of pathogenic
organisms is also an essential element of
wastewater reuse projects, which are being
promoted by a  number of states to help meet
growing water demands and conserve existing
water resources (see box at right). Reuse efforts
are particularly important in areas where water
resources are scarce and where water demands
are high, as well as areas that are subject to
drought. According to the National Drought
Mitigation Center, 41  states experienced water-
related drought impacts, such as lower water
     As of 2001, approximately 280 wastewater
     treatment facilities in California were recycling
     approximately 525,000 acre-feet of water
     per year. California has a goal to increase
     recycling to  I million acre-feet per year by 2010
     (California State Water Resources Control
     Board, 2003).
     As of 2004, Florida had a total of 468 domestic
     wastewater treatment facilities with permitted
     capacities greater than  0.1  MGD that supplied
     a total of 630 MGD of reclaimed water to 440
     water reuse projects. Most of these facilities
     (77%) were located in water resource caution
     areas, which the state defines as areas that have
     critical water supply problems or are projected
     to have critical water supply problems within
     the next 20 years. Florida requires water
     reuse in these areas, unless such reuse  is not
     economically, environmentally, or technically
     feasible as determined by a reuse feasibility
     study (Florida Department of Environmental
     Protection, 2005).
     Facilities in Texas recycle 230 MGD and those
     in Arizona recycle 200 MGD (U.S. EPA  and U.S.
     AID, 2004).
     California, Florida,Texas, and Arizona account
     for the majority of water reuse in the U.S.,
     but other states also have growing programs,
     including Nevada, Colorado, Georgia, North
     Carolina, Virginia, and Washington (U.S. EPA and
     U.S. AID, 2004).
levels, reduced flow, and increased ground water
depletion, in calendar year 2005 (National
Drought Mitigation Center, 2006). Recycled
water can provide a dependable, locally-controlled
water supply that can be used for irrigation,
industrial cooling, vehicle washing, and dust
control, thus reducing private, state, and regional
dependency on natural water supplies. Water reuse
can also:

*   Decrease the diversion of water from sensitive
    ecosystems
*   Decrease the use of scarce water supplies
*   Decrease wastewater discharges
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3. WATER TECHNOLOGY CASE STUDIES
*  Reduce and prevent pollution
*  Create, restore, or enhance wetlands and
    wildlife habitats (U.S. EPA, 2001a).
    To help ensure that the public is protected,
most states have established regulations or
guidelines  that require or recommend treatment
when wastewater is reused (U.S. EPA, 2001a;
U.S. EPA and U.S. AID, 2004). At the federal
level, EPA and the U.S. Agency for International
Development have jointly developed a technical
document  with guidelines for water reuse.
These guidelines recommend a "high degree" of
treatment wherever the public exposure to reused
water is expected. UV disinfection is among the
disinfection processes discussed in the guidelines
(U.S. EPA and U.S. AID, 2004). EPAs Region
9 recommends disinfection for all types of water
reuse, and  reuse is not recommended without
disinfection (U.S.  EPA, 2001a). Similarly, most
states require disinfection for reuse applications,
even those where public access is restricted (U. S.
EPA and U.S. AID, 2004).
   3.4.2  Technology Description
UV disinfection technologies generate
electromagnetic radiation that can penetrate the
cell walls of microbial organisms, damaging their
genetic material and rendering them unable to
reproduce. UV disinfection has certain advantages
and disadvantages over traditional chemical
disinfection technologies (e.g., chlorination), as
shown in Exhibit 3.4-2 (U.S. EPA, 1999a).
       Typically, these UV technologies utilize either
    "low-pressure" or "medium-pressure" mercury
    lamps to generate radiation. Because of their
    higher intensity, medium-pressure lamps disinfect
    faster and have greater penetration capability than
    low-pressure lamps. Medium-pressure lamps,
    however, operate at higher temperatures with
    higher energy consumption (U.S. EPA, 1999a;
    NSF, 2002b). Most UV reactors are contact
    reactors, with the lamps submerged in the water
    to be treated and enclosed in quartz sleeves to
    minimize the cooling effect of the water. There
    also are less common, non-contact reactors
    in which the lamps are suspended outside a
    transparent conduit that carries the water to be
    treated (U.S. EPA, 1999a).
       The ETV Program has evaluated three UV
    disinfection systems, one for secondary wastewater
    effluent and two for water reuse applications. All
    three technologies utilize contact reactors with
    lamps that are enclosed in quartz sleeves. Two of
    the technologies use low-pressure lamps, while the
    third employs medium-pressure lamps. Exhibit
    3.4-3 identifies the ETV-verified technologies
    and provides a description of each.
       All the verification tests were conducted
    at the Parsippany-Troy Hills Wastewater
    Treatment Plant in Parsippany, New Jersey.
    Before verification testing began, the lamps were
    aged for 100 hours to allow the lamp intensity to
    stabilize. The testing used the MS2 bacteriophage
    as the target organism because it has a high
    tolerance for UV light, typically requires a larger
    delivered dose for inactivation than most bacterial
    and viral organisms, and has a consistent dose-
        ADVANTAGES AND DISADVANTAGES OF UV DISINFECTION VERSUS CHEMICAL DISINFECTION
     Advantages

     * Effective at inactivating most viruses, spores, and cysts

     * Eliminates the need to manage toxic, hazardous, or
        corrosive chemicals

     * Might not generate potentially harmful residuals (e.g.,
        trihalomethanes)

     * Can be less intensive to operate


     * Uses shorter contact times
Disadvantages

* Dosage must be sufficient to deactivate certain microorganisms

* Organisms sometimes are able to reverse the destructive effects


* Preventive maintenance is necessary
* Must be designed to account for turbidity and suspended solids in
  wastewater that can reduce the transmittance of the UV radiation

* Does not provide a disinfectant residual, which may be ;
  disadvantage in cases where a residual is desirable.
     * Requires less space for equipment.
     Source: Adapted from U.S. EPA (I999a).
78
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                                                                            3. WATER TECHNOLOGY CASE STUDIES
                          ETV-VERIFIED UV DISINFECTION TECHNOLOGIES FOR
                        SECONDARY WASTEWATER EFFLUENT AND WATER REUSE
     Technology
     Aquionics, Inc. bersonlnLine® 4250 UV System
     Ondeo Degremont, Inc.Aquaray® 40 HOVLS Disinfection
     System

     SUNTEC environmental, Inc. LPX200 UV Disinfection System
     (I)
     (I) No longer in business
     Sources: NSF, 2003c, 2003d, 2003e.
Description
Uses high-output, medium-pressure, mercury lamps in quartz
sleeves that are oriented horizontally and perpendicular to the
direction of flow
Uses high-output, low-pressure, mercury discharge lamps in
quartz sleeves oriented vertically and perpendicular to the
direction of flow
Uses high-output, low-pressure UV lamps in quartz sleeves
oriented horizontally and parallel to the direction of water flow
response over repeated applications. This allows
development of dose-response and delivered dose
relationships that encompass dose levels required
for most disinfection applications. The tests were
conducted on water with UV transmittances of
55 and 65 percent (intended to represent granular
or fabric filtered effluent and membrane filtered
effluent, respectively). Testing at the different
transmittances allows system design that accounts
for different wastewater qualities, thus addressing
one of the disadvantages listed in Exhibit 3.4-
2. All of the verifications measured power
consumption and headloss results, developed
dose-response calibration curves, developed dose
delivery-flow curves, and obtained reactor design
data for use in scaling system designs for larger
applications than those tested (NSF, 2002b,
2003c, 2003d, 2003e). The details  of ETV's
test protocol (NSF, 2002b) differed, however,
depending on the desired application (secondary
effluent treatment or water reuse). These details
are outlined in the protocol, which can be found
at http://www. epa.gov/etv/verificatiom/protocoh-
index.html.
   The technical objective of the tests was to
verify the effective delivered dose for each UV
system's reactor under varying conditions (flow
and water transmittance). Each of the verifications
met this objective, developing dose delivery
curves based on the MS2 bacteriophage survival
rates seen during testing. These curves can be
used to design a UV reactor for an application,
based on site-specific criteria for inactivation of
a target microorganism. The verification reports
for each technology provide more detailed results,
including power consumption and headloss
results (NSF, 2002b, 2003c, 2003d, 2003e). These
reports can be found at http://www.epa.gov/etv/
verifications/vcenter9-5. html.
   3.4.3  Outcomes
The market for the ETV-verified UV disinfection
technologies includes wastewater treatment
facilities that require disinfection, either to meet
discharge requirements or to enable treated water
reuse. In estimating outcomes for the ETV-
verified UV disinfection technologies, the ETV
Program developed three market estimates: an
estimate of the market for UV disinfection in
general ("general market estimate"), an estimate
of the market for UV disinfection specifically for
water reuse applications ("water reuse market
estimate"), and an estimate of the market for
UV disinfection specifically to meet wastewater
discharge requirements ("discharge-related market
estimate").
    The ETV Program used data from EPA's
2000 Clean Watersheds Needs Survey (U.S.
EPA, 2003h, 2003i) to estimate the general
market. In response to the survey, 309 wastewater
treatment facilities reported plans to install new
UV disinfection technology, replace existing
disinfection processes with UV, or expand or
improve their UV disinfection capacity. As
discussed in Appendix F, facilities that reported
plans to add, replace, improve, or expand UV
disinfection could be doing so to meet discharge
requirements, enable water reuse, or both.
Accordingly, the ETV Program used this value
to define the general market for application of
Environmental Technology Verification (ETV) Program
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3. WATER TECHNOLOGY CASE STUDIES
One of the verified UV technologies at a facility in Georgia

the verified UV disinfection technologies.57 The
ETV Program used other data sources to estimate
purpose-specific markets for the verified UV
disinfection technologies. These purpose-specific
market estimates quantify the number of facilities
that could apply the technologies to enable
water reuse (discussed below under "Resource
Conservation and Economic Outcomes") or to
meet discharge requirements (discussed below
under "Regulatory Compliance Outcomes").
    Because the ETV Program does not have
access to a comprehensive set of sales data for the
ETV-verified UV technologies, ETV used two
market penetration scenarios, 10% and 25% of
the market, to estimate the number of facilities
that would install the technologies. Exhibit 3.4-4
shows these estimates.
         PROJECTED NUMBER OF FACILITIES
         THAT WOULD APPLY ETV-VERiFiED
              UV TECHNOLOGIES FOR
         SECONDARY EFFLUENT DISCHARGE
                 AND WATER  REUSE
      Market Penetration
              10%
Number of Facilities
        31
Resource Conservation
and Economic Outcomes
As discussed in Section 2.5.1, EPA and states
generally require or recommend the use of
disinfection when wastewater is reused. Thus, the
feasibility of water reuse depends upon effective
disinfection methods like the ETV-verified
technologies. In addition to the environmental
57 As discussed in Appendix F, this estimate is conservative (low) because it only includes facilities that reported planning to add or
  expand UV disinfection as of the year 2000 as part of projects eligible for funding under the Clean Water State Revolving Fund. All
  told, approximately 4,800 facilities reported that they plan to install, replace, improve, or expand disinfection, but only 309 specifically
  mentioned UV.
80
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                                                                          3. WATER TECHNOLOGY CASE STUDIES
benefits noted above under "Human Health and
Environmental Outcomes" and in Section 2.5.1,
water reuse reduces the need to use scarce water
supplies. Recycled water replaces water that would
otherwise have been taken from these supplies.
   To estimate the market for water reuse,
the ETV Program used data from the Florida
Department of Environmental Protection (2005)
and for the State of California (U.S. Bureau of
Reclamation, 2002). Appendix F describes this
analysis in more detail. Based on the analysis,
the market for the verified technologies in reuse
applications would be 114 facilities (68 in Florida
and 46 in California).58 As discussed in Appendix
F, this reuse market is likely in addition to the
general market defined above and the compliance
market defined below, although there could be
some overlap.
   ETV applied two market penetration
scenarios, 10% and 25% of the reuse market, to
estimate the number of facilities that would install
the technologies for water reuse. As discussed in
Appendix F, ETV also applied average recycling
capacities derived from Florida Department of
Environmental Protection (2005) and U.S. Bureau
of Reclamation (2002) to estimate the quantity of
water that could be recycled by these facilities.59
Exhibit 3.4-5 shows these estimates for the two
market penetration scenarios.
   In addition to conserving resources, water
reuse has an economic impact. The economic
benefits of reuse include avoided alternative water
supply costs, avoided waste discharge costs, and
the economic value of the avoided environmental
impacts. The U.S. Bureau of Reclamation (2002)
         PROJECTED NUMBER OF FACILITIES
           THAT WOULD APPLY THE ETV-
            VERIFIED UVTECHNOLOGIES
              FOR WATER REUSE AND
            THEIR RECYCLING CAPACITY
     Market      Number of Recycling Capacity
     Penetration   Facilities      (MGD)(I)
        /alues rounded to two significant figures
considered all these benefits when estimating the
total net benefit associated with the 34 water reuse
projects identified for implementation by 2010.
After accounting for the costs of the projects, the
US Bureau of Reclamation estimated that a net
benefit of $2.56 billion dollars would be realized.

Regulatory Compliance Outcomes
When applied to treat wastewater effluent, UV
disinfection can assist facilities in complying with
federal and state discharge requirements and water
quality standards. Although such requirements
could include current or potential future standards
for water quality and wastewater discharges, this
analysis  of regulatory compliance outcomes focuses
on EPA's 2005 health-based federal bacteria
standards for states and territories bordering Great
Lakes or ocean waters, and on waters listed as
impaired under section 303 (d) of the Clean Water
Act, both discussed in Section 3.4.1.
    EPA estimated that approximately 90
facilities will have to implement additional or
new treatment to  comply with the new water
quality standards for coastal and Great Lakes
recreation waters (69 FR 67218). In estimating
the cost of the new standards, EPA assumed that
affected facilities will upgrade or adjust existing
chlorination treatment processes to comply
with effluent limitations resulting from the new
standards (U.S. EPA, 2004d; 69 FR 67218). These
facilities, however, also could install the ETV-
verified  UV disinfection technologies, particularly
if they do not have existing chlorination processes,
their chlorination facilities are reaching the end
of their  useful life, or they wish to benefit from
the relative advantages of UV technology over
chemical processes, such as operating cost savings
and reduced space requirements (see Exhibit 3.4-
2). Accordingly, ETV used the EPA estimate of
90 facilities as the market for meeting discharge
requirements. As discussed in Appendix F, this
compliance market is likely in addition to the
general market  and the reuse-specific market
described above, although there could be some
overlap.
    ETV applied two market penetration
scenarios, 10% and 25% of the discharge-related
58 As discussed in Appendix F, this estimate is consetvative because it only includes facilities in Florida and California and the estimate for
  each state is individually conservative.
59 These estimates are conservative because they are based on the conservative estimates of the market for ETV technologies.

Environmental Technology Verification (ETV) Program                                                     81

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3. WATER TECHNOLOGY CASE STUDIES
market, to estimate the number of facilities
that would apply the technologies to meet new
discharge requirements. Exhibit 3.4-6 shows
these estimates for the two market penetration
scenarios.
         PROJECTED NUMBER OF FACILITIES
         THAT WOULD APPLY ETV-VER/F/ED
       UVTECHNOLOGIES TO COMPLY WITH
         NEW WATER QUALITY STANDARDS
     Market Penetration
             10%
Number of Facilities
        9
             25%
        23

    In addition to the facilities shown in Exhibit
3.4-6, as TMDLs are developed for waters
impaired by pathogens, additional facilities could
use the verified technologies to comply with
their discharge requirements under the TMDL
program. As discussed in Section 3.4.1, there are
8,690 river segments, lakes, or estuaries listed
as impaired by pathogens. Facilities discharging
to these impaired waters could benefit from
application of the verified technologies.

Human Health and Environmental Outcomes
Use of the ETV-verified UV technologies will
reduce the occurrence of releases of infectious
organisms in secondary wastewater effluent. Such
treatment ultimately will  reduce exposure of
downstream users to these organisms, reducing the
incidence of diseases and protecting the public's
ability to use natural resources such as beaches
and rivers. In addition to  treating wastewater
effluent to meet discharge requirements, the
ETV-verified technologies also can be used in
water reuse projects, resulting in environmental
benefits like those described in Section 2.5.1.
Also, when UV disinfection replaces chemical
chlorination, it eliminates potential for formation
of harmful residuals like trihalomethanes, which
have been linked to bladder and other cancers (71
FR 388). EPA also believes the evidence supports
concern for potential adverse reproductive
and developmental health effects that might
be associated with these residuals (U.S. EPA,
2005c; 71 FR 388). Finally, replacing chemical
disinfection with UV technologies eliminates the
need for onsite management of toxic, hazardous,
or corrosive chemicals. Installation of the ETV-
verified UV technologies at the facilities shown in
Exhibits 3.4-4, 3.4-5,  and 3.4-6, therefore, would
have human health and environmental benefits.

Financial Outcomes
Although UV technologies can have higher
capital costs than chemical disinfection, they
generally require a smaller footprint than chemical
disinfection technologies (see Exhibit 3.4-2).
Thus, adding UV instead of chemical disinfection
can avoid additional land costs associated
with expanding a treatment facility. Also, UV
technologies can be less labor-intensive to operate,
resulting in reduced labor costs when they replace
chemical disinfection. Finally, UV technologies
avoid the use of chemicals, although they are more
energy-intensive. The cost savings associated
with this advantage depend on the relative cost of
chemicals versus the cost of energy.

Scientific Advancement andTechnology
Acceptance and Use Outcomes
The ETV protocol for validating UV technologies
has been acknowledged by the State of California
as meeting a minimum requirement for acceptance
of a technology under the state's regulations for
UV disinfection, because the protocol touches on
the major points of the National Water Research
Institute/American Water Works Association
Research Foundation UV Disinfection Guidelines
(California Department of Health Services,
2001b).60 This provides an advantage for ETV-
verified vendors in gaining acceptance from the
state regulatory agency and in marketing their
technology in California (U.S. EPA, 2004a). It
also represents the first step in national acceptance
of a standardized protocol, with benefits for
vendors and regulatory agencies (see quote on
next page).
    Vendor information indicates that wastewater
treatment facilities are choosing to install the
ETV-verified UV disinfection technologies.
Examples of facilities that have chosen to install
one vendor's technology (Aquionics) include the
following:
60 The state still requires full-scale commissioning tests to verify performance of the final system design, in addition to ETV verification.

82                                                    Environmental Technology Verification (ETV) Program

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                                                                            3. WATER TECHNOLOGY CASE STUDIES
    Flat Creek Water Reclamation Facility in
    Gainesville, Georgia, which initially installed
    three Aquionics InLine systems treating
    approximately 10 MGD of wastewater in
    2001, added three new Aquionics InLine
    systems in 2004. The additional units allowed
    the facility to expand its treatment capacity
    to 12 MGD and meet new, more stringent
    permit requirements (fecal coliform limits of
    23/100 mL versus 200/100 mL) (Aquionics,
    2004a).
    The City of Fairfield, Ohio, installed two
    Aquionics InLine systems in April 2003
    to handle a wastewater flow capacity of 15
    MGD. The treatment system allowed the
    facility to meet the fecal coliform limits
    established in its permit (Aquionics, 2004b).
    The Laguna County Sanitation District in
    California began operating four Aquionics
    InLine units in April of 2003. The purpose
    of installing the technology was to upgrade
    the quality of the treated water, allowing  it to
    be reused in a greater number of applications
    (including for spray irrigation on edible
    food crops) under the state's water reuse
    requirements. The District chose UV over
    chemical disinfection because of operating
    costs and chemical hazards (see quote at
    right). In October 2005, the District received
    approval from the California Department
    of Health  Services for the Aquionics system
    as meeting the state's water reuse criteria
    (Aquionics, 2003).
         he ETV Program is a success story
         as their protocol has been accepted
by California—as California goes, generally the
rest of the nation tends to follow. What should
occur is that a number of states will adopt the
California protocol .... If there is no uniformity, each
technology can only be demonstrated and accepted
in certain states. It could be extremely costly for
vendors if different protocols had to be developed
in 15 different states. One of the key advantages
of ETV is having a national program—one that
can be accepted by state regulators throughout
the country, and that offers an opportunity for
manufacturers to subject their equipment once
for testing and then have other states accept it.
The states can be confident that the testing was
conducted using a protocol and established quality
assurance procedures, and that the technology
underwent a uniform evaluation by an independent
 hird party."—Karl  Scheible, HydroQual (U.S. EPA,
    •a)
            e knew that we didn't want a chlorine-
            based system because of the high
operating cost and potential hazards  in storing and
handling the needed chemicals ...We really liked
the comparatively low operating and maintenance
costs in addition to the fact that UV  is safe and
leaves no chemicals or other by-products in the
treated water."—Martin Wilder, Laguna County Civil
Engineer Manager (Aquionics, 2003)
                               ACRONYMS USED IN THIS CASE STUDY:
 MGD         million gallons per day

 mL           milliliters
 TMDL         Total Maximum Daily Load
           ultraviolet

           ETV's Water Quality Protection Center
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References

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                                                                                        4. REFERENCES
63 FR 69390. National Primary Drinking Water
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67 FR 1812. National Primary Drinking Water
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U.S. EPA. 2003c. Status of Commercially Available
    Hg CEMS. Prepared by ARCADIS for U.S.
    Environmental Protection Agency.
    3 December. Included in Clean Air Mercury
    Rule Docket Number OAR-2002-0056-0022.
U.S. EPA. 2003d. Air Pollution Control Technology
    Fact Sheet: Fabric Filter—Pulse-Jet Cleaned
    Type.  EPA-452/F-03-025.
U.S. EPA. 2003e. Interim Reregistration Eligibility
    Decision for Atrazine (Case No. 0062). January.
U.S. EPA. 2003f. Revised Atrazine Interim
    Reregistration Eligibility Decision (IRED).
    October.
U.S. EPA. 2003g. Memorandum of Agreement
    Between the  U. S. Environmental Protection
    Agency andAgan Chemical Manufacturing,
    Dow AgroSciences, Drexel Chemical, Oxon Italia
    S.P.A., and Syngenta Crop Protection Concerning
    the Registration of Pesticide Products Containing
    Atrazine. January.
U.S. EPA. 2003h.  Clean Watersheds Needs Survey
    (CWNS) 2000 Unit Process Database, http://
    cfpub. epa.gov/cwns/process. cfm
U.S. EPA. 2003L Clean Watersheds Needs Survey
    2000: Report to Congress. EPA-832-R-03-001.
    August.
U.S. EPA. 2003J. Latest Findings on National Air
    Quality: 2002 Status and Trends. Office of Air
    Quality Planning and  Standards,  Emissions,
    Monitoring, and Analysis Division, Research
    Triangle Park, North Carolina. EPA 4547 K-
    03-001. August.
U.S. EPA. 2003k. Air Pollution Control Technology
    Fact Sheet: Fabric Filter—Reverse-Air/Reverse-
   Jet Cleaned Type with & without Sonic Horn
    Enhancement. EPA-452/F-03-026.
U.S. EPA. 20031. Air Pollution Control Technology
    Fact Sheet: Fabric Filter—Mechanical Shaker-
    Cleaned Type with & without Sonic Horn
    Enhancement. EPA-452/F-03-024.
U.S. EPA. 2004a. Environmental Technology
    Verification (ETV) Program Stakeholder's
    Briefing: Meeting Summary. 11-12 May.
U.S. EPA. 2004b.^zr Quality Criteria for
    Particulate Matter (October 2004). Volume I of
    II. EPA/600/P-99/002aF. October.
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4. REFERENCES
U.S. EPA. 2004c. Nationwide Bacteria Standards
    Protect Swimmers at Beaches. Fact Sheet.
    November. http://www. epa.gov/waterscience/
    beaches/bacteria-rule-final-fs. htm
U.S. EPA. 2004d. Economic Analysis for
    Final Water Quality Standards for Coastal
    Waters. Prepared for Office of Science and
    Technology, U.S. Environmental Protection
    Agency by Science Applications International
    Corporation. Docket Number OW-2004-
    0010-0263. November.
U.S. EPA. 2004e. Inventory of U.S. Greenhouse Gas
    Emissions And Sinks: 1990-2002. EPA 430-R-
    04-003. April 15,2004.
U.S. EPA. 2004f. "Output-based Regulations:
    A Handbook for Air Regulators." Office of
    Atmospheric Programs, Climate Protection
    Partnerships Division. Draft Final Report.
    August.
U.S. EPA. 2004g. Risk Assessment Evaluation
   for Concentrated Animal Feeding Operations.
    EPA/600/R-04/042. May.
U.S. EPA. 2005a. Economic Analysis for the Final
    Long Term 2 Enhanced Surface Water Treatment
    Rule. EPA 815-R-06-001. December.
U.S. EPA. 2005b. Membrane Filtration Guidance
    Manual. EPA 815-R-06-009. November.
U.S. EPA. 2005c. Economic Analysis for the
    Final Stage 2 Disinfectants and Disinfection
    Byproducts Rule. EPA 815-R-05-010.
    December.
U.S. EPA. 2005d. Fact Sheet: Stage2 Disinfectants
    and Disinfection Byproducts Rule. EPA 815-F-
    05-003. December.
U.S. EPA. 2005e. FACT SHEET: EPA's Clean Air
    Mercury Rule. 15 March.
U.S. EPA. 2005f. Regulatory Impact Analysis of the
    Clean Air Mercury Rule. EPA-452/R-05-003.
    March.
U.S. EPA. 2005g. National Emission Inventory Air
    Pollutant Emissions Trends—PM2.5—1990 to
    2002. Updated  4 August.
U.S. EPA. 2005h. PM2.5NonattainmentAreas:
    Point Sources Exceeding Emission Thresholds by
    Pollutant. EPA Docket No. EPA-HQ;OAR-
    2003-0062-0046. September.
U.S. EPA. 2005L Consumer Factsheet on Atrazine.
    Office of Ground Water and Drinking Water.
    February 2005. http://www.epa.gov/safewater/
    contaminants/dw_contamfs/atrazine.html
U.S. EPA. 2005j. Public Drinking Water Systems:
    Facts and Figures.  Office of Ground Water and
    Drinking Water. February, http://www.epa.
    gov/safewater/pws/factoids. html
U.S. EPA. 2005k. Environmental Protection Agency
    Combined Heat and Power Partnership. Last
    updated 2 May. http://www.epa.gov/chp/index.
    htm
U.S. EPA. 20051. EPA— CHP— State Resources-
    Output-based Regulations. Last updated 2 May.
    http://www.epa.gov/chp/state_resources/output_
    based_reg.htm
U.S. EPA. 2005m. Factoids: Drinking Water and
    Ground Water Statistics for 2004. EPA 816-K-
    05-001. May.
U.S. EPA. 2005n. EPA Voluntary Diesel Retrofit
    Program—Glossary of Terms, http://www.epa.
    gov/otaq/retrofit/glossary. htm
U.S. EPA. 2006a. Long Term 2 Enhanced
    Surface Water Treatment Rule (LT2); Basic
    Information. Last Updated 28 February.
    http://www.epa.gov/safewater/disinfection/lt2/
    basicinformation. html
U.S. EPA. 2006b. Fact Sheet: National Air Quality
    Standards for Fine Particle Pollution: Changes to
    Designated "Nonattainment" or "Unclassifiable"
    Areas and Standards for Fine Particle Pollution
    Become Effective. Last Updated 2 March.
    http://www.epa.gov/oar/oaqps/particles/
    designations/documents/AprOS/factsheet.htm
U.S. EPA. 2006c. EPA's BEACH Report: 2005
    Swimming Season. EPA 823-F-06-010. June.
    http://www.epa.gov/ost/beaches/seasons/2005/
U.S. EPA. 2006d. National Section 303(d) List
    Fact Sheet. Accessed 3 May. http://oaspub.epa.
    gov/waters/national_rept.control
U.S. EPA. 2006e. Overview of Current Total
    Maximum Daily Load—TMDL—Program and
    Regulations.  Last Updated 14 March, http://
    www. epa.gov/owow/tmdl/overviewfs. html
96
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                                                                                       4. REFERENCES
U.S. EPA. 2006f. Environmental Technology
    Verification (ETV) Program Case Studies:
   Demonstrating Program Outcomes. EPA/600/
   R-06/001. January.
U.S. EPA. 2006g. CHP Project Resources—
    Wastewater. Last Updated 10 May. http://
   www.epa.gov/chp/project_resources/wastewater.
   htm
U.S. EPA. 2006h. Health and Environmental
   Impacts ofSO2.  Last Updated 2 March, http://
   www. epa.gov/air/urbanair/so2/hlthl.html
U.S. EPA. Undated. Cost Estimates for Mercury
   Emissions Monitoring. U.S. Environmental
   Protection Agency, Clean Air Mercury Rule
   Docket Number OAR-2002-0056-6161.
Utah. 2005. Utah Safe Drinking Water Act.  R309-
   535-13. June.
Utah. 2006. Utah Division of Drinking Water
   Construction Approval Process. Utah
   Department of Environmental Quality. Last
   Updated 19 April. http://www.drinkingwater.
   utah.gov/plan_review_intro. htm
UTC Power. 2006a. Environmental, Educational,
   and Power Security Benefits. Accessed 10 May.
   http://www. utcpower. com/fs/com/l)in/fs_com_
   Page/0,9235,0400,00. html
UTC Power. 2006b. During the Big Blackout, One
   NYC Police Station Kept Its Cool. Accessed 10
   May. http://www. utcpower. com/fs/com/l)in/fs_
   com_Page/0,9235,0400,00. html
Washington. 2001. Water System Design Manual.
   Washington State Department of Health,
   Environmental Health Programs, Division of
   Drinking Water. DOH #331-123. August.
Water & Wastes Digest. 2005. "ITT Aquious-
   PCI Membranes Help Alaska School District
   Win NWRA's Great American Water Taste
   Test."  Water & Wastes Digest. 17 November.
   http://www. wwdmag. com/WWD/index. cfm ?fus
   eaction=sni&nid=10506
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                                        Appendix A.
                                       Methods  for
                   Baghouse  Filtration
                   Products  Outcomes
  Number of Facilities
ETS, RTFs subcontractor during the verifications,
estimates that there are more than 100,000
baghouses in the United States, of which 10,000
are medium to large (McKenna, 2006). Any of
these existing baghouses could install the ETV-
verified products. In addition to these existing
baghouses, there could be other facilities without
existing controls that might be candidates for
installing baghouses using the ETV-verified
products. Because a precise estimate of the
number of facilities nationwide that could apply
the products was not available, ETV limited
its estimate of the market for the ETV-verified
baghouse filtration products to large stationary
sources located in areas of the country that exceed
the NAAQS for PM2 s (i.e., non-attainment
areas). Because these facilities are large and
located in non-attainment areas, they are the most
likely candidates for pollution control as states
implement the NAAQS through their SIPs.
   U.S. EPA (2005h) estimated that there were
358 facilities that each emit more than 100 tons
per year of PM2 s located in non-attainment areas.
The same document estimated there were 443
facilities emitting more than 70 tons per year and
553 facilities emitting more than 50 tons per year.
ETV chose the facilities emitting more than 100
tons per year as its  market estimate because this
group represents the largest facilities, which are
the most likely candidates for control. In addition,
these facilities account for 94% of PM2 5 emissions
from point sources in non-attainment areas.
Facilities that emit between 50 and 100 tons per
year account for only 2% of total PM2S emissions
in non-attainment areas (U.S. EPA, 2005h), so
adding these facilities to the market would have a
limited impact on pollutant reduction estimates.
   The resulting market estimate is conservative
(low) because it considers only large facilities in
non-attainment areas. It does not include smaller
facilities, facilities in areas that meet the NAAQS,
or new facilities that could apply the ETV-verified
technologies. It also does not include facilities
that could require additional control if EPA's
proposed revisions to the NAAQS (71 FR 2620)
are finalized.
  Pollutant Reductions
U.S. EPA (2005h) estimated that the 358 facilities
included in ETV's market estimate emitted
381,400 tons of PM2.S in 2001. To estimate
the portion of these emissions attributable to
baghouses, ETV used data from U.S. EPA (2005g,
1999b, and 1993). First, based on data from U.S.
EPA (2003d, 2003k, and 20031), ETV identified
the following industry categories as amenable to
baghouse technology for PM2 s control:

*  Combustion of coal and wood in electric
   utility, industrial, and commercial/institutional
   facilities
*  Ferrous and non-ferrous metals processing
*  Asphalt manufacturing
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APPENDICES
*  Grain milling
*  Mineral products.
    ETV extracted data from U.S. EPA (2005g)
on 2002 PM2 5 emissions from these selected
industry categories. These industry categories
account for 13% of national PM2S direct
emissions, and an estimated 41% of national
PM2 5 direct emissions from point sources.
    Second, ETV applied assumptions about the
portion of total PM2S emissions in each industry
category attributable specifically to baghouses.
ETV derived these assumptions from data in
U.S. EPA (1999b and 1993)  on the frequency
of baghouse use in three of the most significant
industry categories. Exhibit A-l shows these
assumptions. Applying these assumptions to
the emissions data from U.S. EPA (2005g),
ETV estimated that baghouses account for
PM2 s emissions of 170,000 tons per year, or
approximately 8% of an estimated 2,100,000
million tons per year nationwide from point
sources.61 ETV applied this percentage to the
381,400 tons emitted by large facilities in non-
attainment areas.
    ETV assumed large facilities in non-
attainment areas have existing baghouses with
           a removal efficiency of 95% and that applying
           ETV-verified filtration products would increase
           their efficiency to 99.9%. There is substantial
           uncertainty involved in applying these
           assumptions, because data are not available to
           estimate overall baghouse removal efficiency
           using the ETV-verified filtration products
           or the efficiency of existing baghouses at the
           selected facilities. Pollutant reductions from the
           application of baghouse technologies vary based
           on a number of factors, including gas velocity,
           particle concentration, particle characteristics, and
           cleaning mechanism. Design efficiencies for new
           baghouse devices are between 99% and 99.9%,
           whereas older models  have actual operating
           efficiencies between 95% and 99.9% (U.S. EPA,
           2003d, 2003k, 20031). Also, although removal
           efficiency was not a parameter in the verification
           tests, data in the verification reports show that the
           ETV-verified technologies removed greater than
           99.99% of PM2.S  under the test conditions. The
           ETV results  accurately reflect PM2 s penetration
           of the media, but overall baghouse efficiencies are
           a function of both media penetration and leaks
           through components of the baghouse other than
           the bags.
                ASSUMPTIONS ON PORTION OF EMISSIONS ATTRIBUTABLE TO BAGHOUSES
      Industry Category

      Electric utility coal combustion
      Industrial, commercial, and institutional coal
      combustion
      Industrial wood/bark waste combustion and
      miscellaneous non-residential fuel combustion
      Cement manufacturing
      Other mineral products
      Asphalt manufacturing

      Ferrous and non-ferrous metals processing
      Grain mills (I)
Percent Using
  Baghouses
     18.0
                Source/Notes
Percent using fabric filters + !/2 of percent using combined
technologies in Figure 3-3 of U.S. EPA, 1999b
Percent using fabric filters + !/2 of percent using combined
technologies in Figure 4-5 of U.S. EPA, 1999b
Facilities presumed similar in size and emissions
characteristics to industrial coal combustion facilities
Exhibit 3-4 of U.S. EPA, 1993
     43.8
Cement manufacturing is part of the mineral products
category and other facilities in the category are presumed
similar in industrial processes used and emissions
characteristics.
Facilities presumed similar in industrial processes used and
emissions characteristics to cement manufacturing
Used percentage for electric utilities to be conservative
Used percentage for electric utilities to be conservative
      Values rounded to three significant figures
      (I) Includes wheat mills and other grain mills, but not feed mills because source does not indicate how many feed mills mill grain.
61 ETV derived nationwide point source emissions from U.S. EPA (2005g) by categorizing emissions in the stationary fuel combustion and
   industrial process categories as primarily from point sources and emissions in the transportation and miscellaneous categories as primarily
   from non-point sources.
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                                                                                        APPENDICES
   Based on the assumptions above, the ETV
Program used the following equation to calculate
pollutant reductions:

     PR = ( CE - PE x ( I - 0.999 )) x %MP
Where:
*  PR is PM2.5  reduction in tons per year.
*  CE is current PM2.5 emissions from baghouses
   at large facilities in non-attainment areas, or
   381,400x8%.
*  PE is potential PM25 emissions from
   baghouses  at large facilities in non-attainment
   areas assuming  no existing controls are
   present, or CE / ( I - 0.95), where 0.95 is
   the assumed removal efficiency of existing
   baghouses.
*  0.999 is the assumed removal efficiency
   of baghouses using ETV-verified  baghouse
   filtration products.
*  %MP is the percent market penetration for
   the ETV-verified baghouse filtration products.
   The resulting estimates likely are conservative
(low) because some of the facilities might not
have existing controls in place. They also do not
account for additional reductions that could occur
if EPA's proposed revisions to the NAAQS (71
FR 2620) are finalized.
   To estimate pollutant reductions if the
ETV-verified baghouse filtration products were
applied nationwide, ETV used the same method,
substituting the 170,000 tons per year estimated
above for baghouse emissions nationwide in place
of current emissions (CE).
  Human Health Outcomes
To estimate nationwide human health outcomes,
ETV used data from the RIA for the 1997
NAAQ_S (U.S. EPA, 1997b) and applied the
following equation:

                OutcomeE-rv =
          (Outcome^ / PRR,A) x PREW
Where:
*  OutcomeETV is the quantified measure for a
   given human health endpoint (e.g., avoided
   cases of premature mortality) attributable
   to PM2.5 reductions from the ETV-verified
   baghouse filtration products.
*  OutcomeR|A is the quantified measure for the
   same PM2.5-related human health endpoint
   from Table 12.4 of the RIA for the 1997
   NAAQS (U.S. EPA, I997b) and varied between
   the upper- and lower-bound scenarios.
*  PRmA is the total nationwide PM25 reduction
   estimated in Table 6-5 of the RIA for the 1997
   NAAQS (U.S. EPA, I997b).
*  PREw is the PM25 reduction estimated from
   application of the ETV-verified baghouse
   filtration products in each market penetration
   scenario.
   This method assumes there would be a linear
relationship between human health outcomes and
emissions reductions. This method is most likely
a simplification of the actual relationship. First, it
assumes that the relationship between emissions
reductions and the ambient concentration of
PM2 s in a given area is linear. Second, it assumes
that the relationship between ambient PM
concentrations and human health effects is linear.
In fact, these relationships are complex and
subject to external factors (e.g., state NAAQS
implementation strategies, PM emissions from
other sources, other environmental factors, and the
population in a given area). Data are not available
to  determine how close the overall relationship
among these factors is to linear. Finally, the
method assumes that the nationwide distribution
of PM2 5 reductions from the ETV technologies
would be similar to that from the 1997 NAAQS.
This assumption could be reasonable for very
high market penetration scenarios. It is likely less
accurate for lower market penetration scenarios,
where penetration might occur first in certain
areas of the country. In spite of these limitations,
the resulting estimates could be conservative
(low) because they are based on the conservative
estimates of pollutant reductions.
  Economic Outcomes
To estimate the economic value of human health
and environmental benefits, the ETV Program
used values for total annual benefits from the
RIA for the 1997 NAAQ_S (U.S. EPA, 1997b)
and a method parallel to that discussed above for
human health outcomes. That is, ETV applied the
following equation:
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APPENDICES
     BenefitsETV = (BenefitsR,A / PRR,A) x PREW
Where:
*  BenefitsEW is the total monetary benefit per
    year realized from the human health and
    environmental outcomes associated with PM2.5
    reductions from the ETV-verified baghouse
    filtration products.
*  BenefitsR|A is the total monetary benefit per
    year reported in Tables 12.5  (for human
    health benefits) and  12.13 (for environmental
    benefits, including  consumer cleaning cost
    savings and visibility improvements) of the RIA
    for the 1997 NAAQS (U.S. EPA, !997b).These
    values varied between the upper- and lower-
    bound scenarios.
*  PRmA is the total nationwide PM2.5 reduction
    estimated in Table  6-5 of the RIA for the 1997
    NAAQS (U.S. EPA, 1997b).
*   PREw is the PM2.5 reduction estimated from
    application of the ETV-verified baghouse
    filtration products in each market penetration
    scenario.
    In addition to monetary benefits associated
with human health outcomes, ETV included
monetary benefits associated with environmental
outcomes (consumer cleaning cost savings and
visibility improvements) in this calculation.
This method is subject to the same limitations
discussed above for human health outcomes. In
spite of these limitations, the resulting estimates
could be conservative for the same reasons
discussed above, and because they are in 1990
dollars, as reported in the RIA. Therefore, they
provide a conservative (low) estimate of economic
outcomes in current year dollars.
 104
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                                           Appendix  B.
                                          Methods  for
                    Fuel   Cell   Outcomes
  Number and Capacity of
  ETV-Verified Fuel Cells
The ETV Program used data from Fuel
Cells 2000's Worldwide Stationary Fuel Cell
Installation Database (Fuel Cells 2000,2006) to
estimate the number and capacity of ETV-verified
fuel cells that have been installed in the United
States since the verifications were completed.
Specifically, to estimate current installations,
ETV searched the database for all U.S. projects
involving PAFC fuel cells installed by UTC
Power and PEM fuel cells installed by PlugPower
and examined the details of each project found.
In determining whether to count a given project,
ETV included PureCell™ and PureComfort™
systems from UTC Power and GenSys systems
from PlugPower. Although these technology
names are not the same as those in the verification
reports (PC25 and SU1), information from the
vendor Web sites indicates that these are likely
new brand names for the same technology.62 ETV
also included projects where the technology name
was not specified, if the fuel cells were of the same
capacity as those verified. ETV excluded from its
count the following types of projects:

*  Projects installed before the verifications were
   completed (1998 for UTC Power and 2003
   for PlugPower)
*  Projects that provide backup or emergency
   power only
*  Projects that have been decommissioned or are
   no longer operating
*  Short-term demonstration projects.
   Using these guidelines, ETV estimated 134
verified fuel cells, with a total of approximately 15
MW of capacity, have been installed in the United
States since verifications were completed and are
currently operating. This estimate is conservative
(low) in terms of number and capacity because
it excludes projects that provide backup or
emergency power only. These projects, however,
likely operate only intermittently and would
not contribute significantly to annual pollutant
reductions. The estimate also is conservative
because it excludes short-term demonstration
projects. Some of these demonstration fuel cells
might have remained in place and continued
operating after the demonstration was complete,
continuing to contribute to pollutant  reductions.
   To project future installations, the ETV
Program examined projects that were installed
in 2005. In making the projection, however,
ETV did not include future installations of the
PlugPower technology. Information from the
vendor Web site and media sources (see, for
example, Engle, 2005) suggest the company is
now targeting the backup power market using
hydrogen fuel directly, without a fuel  reformer.
Although verification results might contribute to
future sales of the technology in backup power
applications, the resulting installations would not
contribute significantly to pollutant reductions.
62 The technology vendors were provided an opportunity to review this case study and did not comment on this assumption.

Environmental Technology Verification (ETV) Program                                          105

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APPENDICES

Excluding 2005 PlugPower sales, 18 fuel cells,
with a total capacity of 3.8 MW, were installed
in 2005. The ETV Program used this estimate
of fuel cells installed in 2005 to project future
installations over the next five years as follows:
       18 fuel cells x 5 years = 90 fuel cells
           3.8 MW x 5 years = 19 MW
    Adding these values to 134 fuel cells currently
installed, with 15 MW capacity, results in a future
projection of 224 fuel cells with 34 MW capacity.
This projection is conservative (low) because it
excludes future PlugPower sales and assumes no
growth in sales from 2005 levels.
   Emissions Reductions
In developing the current estimate and future
projection, the ETV Program maintained separate
estimates in three categories, for use in estimating
emissions reductions:
1)  Small, residential-scale fuel cells operating on
    conventional fuels
2)  Larger, commercial/institutional-scale fuel
    cells operating on conventional fuels
3)  Larger, commercial/institutional-scale fuel
    cells operating on anaerobic digester gas
    Emissions reductions from fuel cell
applications vary on a site-by-site basis. Because
of this variation, producing a precise nationwide
estimate is difficult. To produce a rough estimate,
the ETV Program assumed that applications that
fell within the same fuel cell category produced
identical emissions reductions. For categories
                                                1 and 3, the ETV Program used the reduction
                                                estimates developed by Southern Research
                                                Institute in the verification reports to estimate
                                                the emission reductions from installations within
                                                those categories. For category 2, ETV modified
                                                the reduction estimate for one of the test sites to
                                                subtract the credit for eliminating emissions from
                                                the digester gas flare. Exhibit B-l summarizes
                                                the category-specific reduction estimates. The
                                                verification reports  (Southern Research Institute,
                                                1998,2003c, 2004b) describe the test sites and the
                                                baseline assumptions (e.g., displaced conventional
                                                power source) used to generate the reduction
                                                estimates in more detail. The reduction estimates
                                                account for CO2 emissions from the fuel reformer
                                                or gas processing units associated with the fuel
                                                cells.
                                                   To calculate national emissions reductions
                                                for each category, the ETV Program used the
                                                following equation:
                                                         RTOTAL = (CTOTAL / C) x R / 2000
                                                Where:
                                                *  RTOTAL is  total CO2 or NOx reduction for a
                                                   given category in tons per year.
                                                *  CTOTAL is the total capacity in MW of ETV-
                                                   verified fuel cells installed and varies for
                                                   each category and for current and future
                                                   installations.
                                                *  C is the individual fuel cell capacity in MW for
                                                   the given category.
                                                *  R is the  model site CO2 or NOx reduction  in
                                                   pounds per year and varies for each category.
                                                   ETV then summed the results for each
                                                category to estimate total national emissions
                                                reductions.
                                   Fuel Cell
                                   Capacity
                                    (kW)
                                      5
                                         CO2 Reduction   NOx Reduction
      Category and
       Facility Type
I) Small, residential-scale fuel cells
operating on conventional fuels
(pounds
per year)
   723
(pounds
per year)
  44.3
Southern Research Institute
2003c,Table 2-8
                                                                               Southern Research Institute
                                                                               2004b,Table 2-6, subtracting
                                                                               credit for eliminating flare
2) Larger, commercial/institutional
scale fuel cells operating on
conventional fuels
                                                                               Southern Research Institute
                                                                               2004b,Table 2-6
3) Larger, commercial/institutional-
scale fuel cells operating on
anaerobic digester gas
Values rounded to three significant figures
 106
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                                     Appendix  C.
     Methods  for Microturbinel
               Combined  Heat  and
     Power  (CHP)  Outcomes
  Microturbine/CHP Markets
As discussed in Section 2.4.3, one vendor has
reported sales of 13 MW of ETV-verified
microturbines for CHP applications in the United
States since the verifications were completed
(ETV Vendor, 2006). The ETV Program used
this value as the current minimum market
penetration. This is a conservative (low) estimate
because it includes sales by only one vendor.
The vendor also reported sales of approximately
8.4 MW for CHP applications in the United
States during 2005 (ETV Vendor, 2006). The
ETV Program used 2005 sales to calculate future
penetration over the next five years as follows:
        8.4 MW x 5 years = 42 MW
  Adding this value to the current minimum
penetration of 13 MW results in a total installed
capacity of 55 MW. This estimate also is
conservative (low) because it is based on the
conservative estimate of current penetration and
assumes no growth in sales. The vendor forecasts
sales will double this year and double again
the following year (ETV Vendor, 2005). It also
includes U.S. sales only. The vendor reported that
U.S. sales represented approximately half of its
global sales (ETV Vendor, 2005). Also, various
economic estimates of the microturbine/CHP
market project an increasing market for these
technologies, as discussed below.
  EEA (2003) reports that current microturbine
sales in  CHP applications average 50 units per
year. Assuming an average capacity per unit in the
range reported for the ETV-verified technologies
(30 to 75 kW), current sales as reported by EEA
(2003) translate to 1.5 to 3.75 MW of capacity
per year. The same source, however, estimates an
increasing market for these technologies: 1,530
MW in CHP applications, both new and retrofit,
over the next 20 years. This translates to sales of
76.5 MW per year. This latter estimate assumes
advances in technology that result in greater
efficiency and cost-effectiveness than achieved
by current technology. Another estimate of the
microturbine market can be derived from data
in Boedecker et al. (2000). This source estimates
microturbines will generate 1 billion kWh in
2010 and 3 billion kWh in 2020. The capacity
required to generate this much electricity would
be a minimum of 57 MW in 2010 and 171 MW
in 2020.63 This capacity increase would require
microturbine sales of 114 MW over ten years, or
11.4 MW per year. Exhibit C-l compares the
estimates used in this analysis with the projections
from these economic analyses. The estimates used
in this analysis are at the lower end, but within,
the range from the economic analyses.
  Emissions Reductions
Emissions reductions from microturbine
applications vary on a site-by-site basis. Because
of this variation, producing a precise nationwide
estimate is difficult. To produce a rough estimate,
63 These capacity estimates assume 100% utilization of installed capacity, and are, therefore, low.

Environmental Technology Verification (ETV) Program                                     107

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APPENDICES
                        Sales per year
                            (MW)
                           1.5 to 3.75
Total over five years
      (MW)
     7.5 to 18.8
     Source
EEA, 2003
         Comments/Limitations
Based on current sales averaged over the last 20 years
Includes CHP applications only.
Based on sales by a single vendor (ETVVendor, 2006).
Assumes no growth in sales.
Includes CHP applications only.
Based on 100% capacity utilization.
Assumes limited technology advancement.
Assumes technology advancement.
Includes CHP applications only.
      Estimate used in ETVs
      analysis
      Boedecker et al., 2000

      EEA, 2003
the ETV Program calculated the total emissions
reductions assuming all applications are identical
and represented by model sites. The ETV
Program examined several possible model sites, all
developed by Southern Research Institute in the
verification reports for the technologies. Exhibit
C-2 summarizes the model sites examined. The
verification reports (Southern Research Institute,
2001a, 2003a, 2003b) describe the model sites
and the baseline assumptions (e.g., displaced
conventional power source) used to generate
the reduction estimates in more detail. For the
estimates in this analysis, the ETV Program used
only the first two sites in Exhibit C-2 for the
following reasons:

*  The estimates for these sites are based
    on actual test site operations (as opposed
    hypothetical sites).
*  The estimates include both CO2 and NOX
    reductions.
            *  The estimates were developed using more
               recent assumptions about displaced emissions
               rates.
               The ETV Program generated upper- and
            lower-bound estimates for CO2 and NOx by
            choosing the model sites that result in the highest
            and lowest CO2 and NOX reductions, respectively.
            The national estimates use the following equation:

                      TR = (TC / MC) x MR / 2000
            Where:
            *  TR is total CO2 or NOX reduction in tons per
               year.
            *  TC is the total capacity in  MW of ETV-verified
               microturbines installed and varies depending
               on the market penetration scenario.
            *  MC is the model site capacity in MW and
               varies depending on the model site chosen.
            *  MR is model site CO2 or NOX reduction in
               pounds per year and varies depending on the
               model site chosen.
 108
               Environmental Technology Verification (ETV) Program

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                                                                                                                  APPENDICES
     Location and
     Facility Type
New York, Community
Center (e)(I)
New York, Supermarket

Chicago, Large Office (h)
Chicago, Medium Hotel (h)
Chicago, Large Hotel (h)
Chicago, Hospital (h)
 \tlanta, Large Office (h)
Atlanta, Medium Hotel  (h)
Atlanta, Large Hotel (h)
Atlanta, Hospital (h)
Values rounded to three significant figures
(h) Hypothetical site
(e) ETV test  site
(I) Used to generate lower-bound CO2 estimates
(2) Used to generate upper-bound CO2 estimates
                                                     328,000
                                                     527,000
                                                     558,000
                                                     884,000
                                                   3,920,000
                                                   1,050,000
                                                   1,160,000
                                                   1,700,000
                                                   9,770,000
1,060
Not estimated
Not estimated
Not estimated
Not estimated
Not estimated
Not estimated
Not estimated
Not estimated
Southern
Southern
Southern
Southern
Southern
Southern
Southern
Southern
Southern
Research
Research
Research
Research
Research
Research
Research
Research
Research
Institute,
Institute,
Institute,
Institute,
Institute,
Institute,
Institute,
Institute,
Institute,
2003 b
200 la
200 la
200 la
200 la
200 la
200 la
200 la
200 la
and upper-bound
and lower-bound
                                                                  NOx estimates
                                                                  NOx estimates
Environmental Technology Verification (ETV) Program
                                                                     109

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                                      Appendix  D.
                                      Methods  for
                Microfiltration  (MF)
       and  Ultrafiltration  (UF)
                                            Outcomes
  Number of Systems
  and Population Served
For the LT2ESWTR, EPA examined several
different Cryptosporidium occurrence data sets:
the Information Collection Rule (ICR) data set,
the Information Collection Rule Supplemental
Survey of Medium Systems (ICRSSM) data
set, and the Information Collection Rule
Supplemental Survey of Large Systems (ICRSSL)
data set. Differences among these data sets
resulted in different estimates of the number of
public water systems (PWSs) required to install
treatment. The ETV Program used this range
of estimates to select upper- and lower-bound
estimates of the number of small PWSs that could
install the verified technologies. Specifically, the
ETV Program used data from Table VI-D.3 of
71 FR 654. For the upper-bound estimate, the
ETV Program used the number of small systems
corresponding to the ICR data set. For the
lower-bound estimate, the ETV Program used
the number of small systems corresponding to
the ICRSSL data set.64 The resulting upper- and
lower-bound estimates are 2,200 and 1,400 small
systems, respectively. To produce the estimates
in Exhibit 3.1-2, the ETV Program multiplied
the total number of systems by each market
penetration percentage. These upper- and lower-
bound estimates of the number of systems also
correspond to upper- and lower-bound estimates
of human health outcomes and economic benefits.
   The ETV Program also estimated the total
population served by these systems. This estimate
used an average population served per system
by small systems derived from Exhibit 5.9 of
U.S. EPA (2005a). To produce the population
estimates in Exhibit 3.1-2, the ETV Program
multiplied the number of systems in each market
penetration scenario by this average population
per system.
  Human Health Outcomes
The ETV Program estimated the
cryptosporidiosis cases prevented by ETV-verified
MF and UF technologies by assuming a straight-
line relationship between market penetration
for the technologies and the total estimated
cryptosporidiosis cases prevented at small PWSs
by the LT2ESWTR as a whole. That is, the ETV
Program applied the following equation:
64 The ICR data set describes a source water occurrence pattern with a greater frequency of high oocyst concentrations than either the
  ICRSSM or ICRSSL system data sets (U.S. EPA, 2005a). Therefore, the ICR data set results in a larger estimate of the number of
  systems installing treatment, with greater human health and economic benefits. Accordingly, the ETV Program chose the data associated
  with the ICR data set for use in its upper-bound estimates. Of the three data sets, the ICRSSL data set results in the lowest estimates
  of the number of systems installing treatment and human health and economic benefits. Therefore, the ETV Program chose the data
  associated with the ICRSSL data set for use in its lower-bound estimates.
Environmental Technology Verification (ETV) Program
                                 II

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APPENDICES
           CasesEW = CasesEA x %MP
Where:
*  CasesEW is the number of cryptosporidiosis
    cases per year prevented by ETV-verified MF
    and UF technologies.
*  CasesEA is the number of cryptosporidiosis
    cases per year prevented at small systems by
    the LT2ESWTR.
*  %MP is the percent market penetration for
    the ETV-verified MF and UF technologies.
    CasesEA varied for the upper- and lower-
bound scenarios based on the range of estimates
shown in U.S. EPA (2005a) and presented in
Exhibit D-l. Specifically, the upper-bound value
corresponds to the ICR data set and the lower-
bound value corresponds to the ICRSSL data
set. The ETV Program's method assumes the
characteristics (e.g., Cryptosporidium occurrence,
average population served) of systems  applying
the ETV technologies are distributed in the same
manner as those of all affected small PWSs. This
assumption might be reasonable for very high
market penetration scenarios. It is likely less
accurate for lower market penetration  scenarios,
where penetration might occur first in certain
areas of the country. In spite of this limitation,
the resulting estimates represent the resulting
estimates represent reasonable, conservative (low)
estimates of human health outcomes attributable
to the ETV-verified MF and UF technologies.
   Economic Outcomes
To estimate the economic value of
cryptosporidiosis cases and associated deaths
prevented, the ETV Program used values for
total annual benefits from EPA's EA for the
LT2ESWTR (U.S. EPA, 2005a). That is, the
ETV Program applied the following equation:

         Benefits,:-™ = BenefitsFA x %MP
Where:
*  BenefitsE-rv is the total monetary benefit per
    year realized by preventing cryptosporidiosis
    and associated death by employing ETV-
    verified MF and UF technologies.
*  BenefitsEA is the total monetary benefit per
    year realized by the implementation of the
    LT2ESWTR at small systems.
*  %MP is the percent market penetration for
   the ETV-verified MF and UF technologies.
   BenefitsEA varied for the upper- and lower-
bound scenarios, based on the range of estimates
presented in U.S. EPA (2005a)  and presented
in Exhibit D-l. This range of estimates resulted
from the different data sets examined for the
rule and differing assumptions about the value of
avoiding cryptosporidiosis cases and the discount
rate. For the upper-bound estimate, the ETV
Program used the total annual benefits annualized
at 3%, based on enhanced cost of illness, from
the ICR data set. For the lower bound, the ETV
Program used the total annual benefits annualized
at 7%, based on traditional cost of illness, from the
ICRSSL data set.
   To develop the pilot cost savings estimates, the
ETV  Program assumed a total pilot study cost of
$20,000 per individual system. This assumption
is based on a vendor estimate of $100,000 total
in pilot testing costs for five installations of an
ETV-verified membrane drinking water treatment
technology (other than one of the ETV-verified
MF and UF technologies) (Adams, 2005). There
can be significant variation in individual pilot
study  costs, depending on site-specific factors,
state agency requirements, and technology type.
The assumption, however, is within the lower part
of the range ($1,000 to $60,000) assumed for pilot
testing costs for the LT2ESWTR (Cadmus and
Pirnie, 2003). It also is at the low end of the range
of costs for ETV testing ($20,000 to $30,000)
(Bartley, 2005).
   To address some of the uncertainty associated
with individual pilot study costs, the ETV
Program developed two scenarios. The lower
bound assumes ETV verification eliminates the
need for pilot studies for 10% of systems installing
ETV-verified technologies (or reduces pilot study
costs by 10%). The upper bound assumes ETV
verification eliminates  the need for pilot studies
for 75% of systems installing ETV-verified
technologies (or reduces pilot study costs by 75%).
Using these assumptions, the ETV Program
estimated pilot cost savings using the following
equation:
                = Potential Market x %MP
            x $20,000 x Reduction
  12
   Environmental Technology Verification (ETV) Program

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                                                                                              APPENDICES
Where:
*   SavingsETV is the total pilot study cost savings
    from employing ETV-verified MF and UF
    technologies.
*   Potential Market is the number of facilities in
    the market, which varied for the upper- and
    lower-bound scenarios, as discussed above.
>%MP is the percent market penetration for the
   ETV-verified MF and UF technologies.
*   Reduction is the percent reduction in pilot
   study costs or percent of facilities for which
   ETV data eliminates the need for a pilot study
   (10% in the lower bound and 75% in the
   upper bound).
           ASSUMPTIONS USED TO DEVELOP HEALTH AND ECONOMIC OUTCOME ESTIMATES
     Variable
Total cases prevented at small systems (I)

Fatal cases prevented at small systems

Total cases prevented including large systems (I)

Fatal cases prevented including large systems
^^^•^^^^^^^^^^^^^•B
Small systems (I)

Including large systems (I)
                 Lower-Bound
                 Assumption
                     11,000
                       I
                                                                        Source and
                                                                        Derivation
                                                                                       U.S. EPA (2005a),
                                                                                       Exhibits 5.16 and
                                                                                       5.17
                                                                                       U.S. EPA (2005a),
                                                                                       Exhibits C.4a and
                                                                                       C.Sf
     (I) Values rounded to two significant figures

Environmental Technology Verification (ETV) Program
                                            113

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                                           Appendix  E.
                                         Methods  for
  N a no filt rat ion   Outcomes
  Number of Systems
  and Population Served
In estimating the market for the ETV-verified
PCI nanofiltration technology, the ETV Program
included small systems projected to install
technology as a result of either the Stage 1 or
Stage 2 DBPR. Although systems were required
to comply with the Stage 1 DBPR by January
2004, the ETV verification was completed
in September 2000. Therefore, some Stage 1
systems could have chosen the PCI nanofiltration
technology on the basis of the verification results
and it is appropriate to include these systems in
the market estimate. To estimate the market of
Stage 1 systems, the ETV Program used data
from Tables IV-2 and IV-3 of 63 FR 69390.
These data result in a potential market from
Stage 1 of approximately 3,100 small systems.
The ETV Program included only small systems
that were projected to select membranes as the
compliance technology for Stage 1. The ETV
Program limited the market estimate to systems
projected to select membranes because some
of the other compliance technologies (e.g.,
enhanced coagulation) represent modification of
existing treatment technologies and, therefore,
would be expected to be less costly than a
new membrane process. Also, because systems
installing membranes to comply with Stage 1
would be unlikely to require additional technology
to comply with Stage 2, using membrane
systems only ensures no double counting of
systems between the Stage 1 and Stage 2 market
estimates. The resulting Stage 1  estimate is
conservative (low) because some systems projected
to install technologies other than membranes in
1998 might have chosen a membrane technology
instead.
   To estimate the market of Stage 2 systems,
the ETV Program used data from the EA
(U.S. EPA, 2005c) - specifically from the rows
of Exhibit 7.3 that represent systems serving
less than 10,000 people. These data result in a
potential market from Stage 2 of approximately
1,700 small systems. Although the EA forecast
that few systems would use nanofiltration for
compliance with the Stage 2 DBPR (Chen, 2005;
U.S. EPA, 2005c), EPA did list nanofiltration as
a BAT for the Stage 2 rule and found that some
small systems could find nanofiltration cheaper
than another BAT alternative, granular activated
carbon (71 FR 388). The ETV Program then
added this market to the Stage 1 market, resulting
in a potential market of approximately 4,800
small systems. The resulting market estimate is
conservative (low) because, in addition to the
Stage 1 market estimate being conservative, the
overall estimate does not include systems that
might adopt the technology to treat for other
contaminants.
   To produce the estimates in Exhibit 3.2-1,
the ETV Program multiplied this total by each
market penetration percentage. The resulting
estimates are reasonable in comparison to vendor
estimates of the market. The vendor estimated
that 200 to 250 systems in Alaska alone could
adopt the technology and reported other markets
in Washington, Oregon, Maine, Vermont, and
New Hampshire (NSF, 2004).
Environmental Technology Verification (ETV) Program
                                    15

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APPENDICES
    The ETV Program also estimated the total
population served by these systems. This estimate
used an average population served per system,
by system size category and type (ground water
versus surface water), derived from Tables IV-1,
IV-2, IV-3, and IV-7 of 63 FR 69390 for Stage
1 systems and Exhibits 3.2 and 3.3 of U.S. EPA
(2005c) for Stage 2. To produce the population
estimates in Exhibit 3.1-2, the ETV Program
multiplied the number of systems in each category
in each market penetration scenario by the
appropriate average population per system.
   Human Health Outcomes
Because the verified technology would likely result
in compliance with both the Stage 1 and Stage
2 DBPRs, it is appropriate to consider human
health outcomes from both rules at each system
applying the technology. For Stage 1, the ETV
Program estimated the number of cancer cases
avoided by applying the ETV-verified technology
by assuming a straight-line relationship between
the number of bladder cancer cases prevented
by the rule and the total population served by
systems installing or modifying treatment. That is,
the ETV Program applied the following equation:

    OutcomeETVs, = (Outcomes, /TPS,) xTPETV
Where:
*   OutcomeETVs, is the estimated number of
    bladder cancer cases per year associated with
    Stage I prevented by the PCI nanofiltration
    technology.
*   Outcomes, is 2,232 bladder cancer cases per
    year, the total prevented by the Stage I  DBPR
    (from 63 FR  69390).
*   TPS, is approximately I 10 million people,
    the total population served by all systems
    installing treatment as a result of the Stage I
    DBPR (derived from Tables IV-1, IV-2, IV-3, and
    IV-7 of 63 FR 69390).
*   TPETV is the total  population served
    by systems applying the ETV-verified
    technologies in each market penetration
    scenario.
    For Stage 2, the ETV Program estimated
the bladder cancer cases prevented by the PCI
nanofiltration technology by assuming a straight-
line relationship between market penetration for
the technology and the total estimated bladder
cancer cases prevented at small ground and surface
water systems by the Stage 2 DBPR. That is, the
ETV Program applied the following equation:

                    = Outcome^ x %MP
                              'S2
Where:
*  OutcomeEW,s2 is the estimated  number of
   bladder cancer cases per year associated with
   Stage 2 prevented by the PCI nanofiltration
   technology.
*  OutcomeS2 is 12.5 bladder cancer cases per
   year, the total prevented at small systems by
   the Stage 2 DBPR (from Exhibit ES.5 of U.S.
   EPA, 2005c).
*  %MP is the percent market penetration for
   the PCI nanofiltration technology.
   The ETV Program then added together
OutcomeETv,si and OutcomeETv,s2- This addition
is reasonable, because the avoided bladder
cancer cases reported for the Stage 2 rule are
incremental (i.e., in addition to those prevented
by Stage 1). This method incorporates several
key assumptions. First, it assumes that a
causal relationship exists between exposure to
chlorinated water and bladder cancer. EPA and
the international bodies that classify risk recognize
that such causality has not yet been established.
This assumption means that the  actual number of
bladder cancer cases prevented could be as low as
zero both for the PCI technology and the Stage 1
and Stage 2 DBPRs. Second, the method assumes
that the risk of bladder cancer from drinking
water increases linearly with increasing average
concentrations of TTHM and HAAS in drinking
water and that the number of cases occurring each
year in the population served by  disinfecting water
supplies is directly proportional to the average
DBP levels in those systems. This assumption is
identical to that used in the Stage 1 and Stage
2 rules. Finally, the method assumes that the
nationwide distribution of DBP  reductions from
the PCI technology would be similar to that from
the DBPRs as a whole. This assumption might
be reasonable for very high market penetration
scenarios. It is likely less accurate for lower market
penetration scenarios, where penetration might
occur first in certain areas of the  country. In
spite of these limitations, the resulting estimates
  16
   Environmental Technology Verification (ETV) Program

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                                                                                          APPENDICES
represent reasonable, conservative (low) estimates
of human health outcomes attributable to the PCI
technology.
  Economic Outcomes
To estimate the economic value of bladder cancer
cases prevented, the ETV Program used unit
values per case derived from Exhibit ES.5 of the
EA for Stage 2 (U.S. EPA, 2005). This source
presents a range of total economic values for four
different scenarios based on differing assumptions
about the value of a non-fatal bladder cancer case
and the discount rate. Exhibit E-l shows the
unit values derived from the totals for these  four
different scenarios. For the upper-bound estimate,
the ETV Program multiplied the highest unit
value per case by the estimate of bladder cancer
cases prevented per year. For the lower-bound
estimate, the  ETV Program multiplied the lowest
unit value per case by the estimate of bladder
cancer cases prevented per year.
   An alternate method for estimating economic
value would be to use unit values per case from
the Stage 1 rule ($587,500 per non-fatal case,  $5.6
million per fatal case, and a 23% mortality rate).
These unit values would produce lower estimates
than the lower-bound estimates using the Stage
2 unit values  ($14 million and $35 million in
1998 dollars at 10% and 25% market  penetration,
respectively).  The ETV Program chose, however,
to use the Stage 2 unit values (which  are in 2003
dollars), because they are based on more recent
economic data.
   To develop the pilot cost savings estimates, the
ETV Program assumed a total pilot study cost of
$20,000 per individual system. This assumption
is based on a vendor estimate of $100,000 total
in pilot testing costs for five installations of the
PCI technology (Adams, 2005). There can be
significant variation in individual pilot study
costs, depending on site-specific factors, state
agency requirements, and technology type. The
assumption, however, is within the lower part
of the range typically assumed for pilot testing
costs in EPA regulatory analyses.65 It also is at
the low end of the range of costs for ETV testing
($20,000 to $30,000) (Bartley, 2005).
    To address some of the uncertainty associated
with individual pilot study costs, the ETV
Program developed two scenarios. The lower
bound assumes ETV verification eliminates the
need for pilot studies for 10% of systems installing
ETV-verified technologies (or reduces pilot study
costs by 10%). The upper bound assumes  ETV
verification eliminates the need for pilot studies
for  75% of systems installing ETV-verified
technologies (or reduces pilot study costs by 75%).
Using these assumptions, the ETV Program
estimated pilot cost savings using the following
equation:

         SavingsETv =  Potential Market x
          %MP x $20,000 x Reduction
Where:
*   SavingsETV is the total  pilot study cost savings
    from employing the PCI nanofiltration
    technology.
*   Potential Market is the number of facilities in
    the market, as discussed above.
*   %MP is the  percent market penetration
    for the  ETV-verified the PCI nanofiltration
    technology.
*   Reduction is the percent reduction in pilot
    study costs or percent of facilities for which
    ETV data eliminates the need for a pilot study
    (10% in the lower bound and 75% in the
    upper bound).
65 For example, for the Long Term 2 Enhanced Surface Water Treatment Rule, EPA estimated that the cost of pilot testing for membrane
  drinking water treatment technologies could range from $1,000 to $60,000 per facility. (Cadmus and Pirnie, 2003)

Environmental Technology Verification (ETV) Program                                                    I 17

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APPENDICES
                    UNIT ECONOMIC VALUE PER CASE OF BLADDER CANCER PREVENTED
Discount
   Rate    Value of a Non-fatal Bladder Cancer Case
           Same as value of avoiding a case of curable lymph cancer (lymphoma) (I)
           Same as value of avoiding a case chronic bronchitis
           Same as value of avoiding a case of curable lymph cancer (lymphoma)
           Same as value of avoiding a case chronic bronchitis (2)
Data derived from Exhibit ES.5 of the EA for Stage 2 (U.S. EPA, 2005c)
Values rounded to two significant figures
(I) Used in upper-bound estimate
(2) Used in lower-bound estimate
          3%
          7%
                   Value per Bladder Cancer
                   Case Prevented ($ millions)
                               5.5
                              •
                               4.4
 118
Environmental Technology Verification (ETV) Program

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                                    Appendix F.
      Methods  for  Ultraviolet
             (UV)  Disinfection  for
        Secondary  Wastewater
                                  Effluent  and
      Water  Reuse  Outcomes
In estimating outcomes for the ETV-verified
UV disinfection technologies, the ETV Program
developed three market estimates: an estimate
of the market for UV disinfection in general
("general market estimate"), an estimate of
the market for UV disinfection specifically for
water reuse applications ("water reuse market
estimate"), and an estimate of the market for
UV disinfection specifically to meet wastewater
discharge requirements ("discharge-related market
estimate"). This appendix describes the derivation
of each estimate and discusses the potential for
overlap among the three estimates.
  General Market Estimate
For the general market estimate, the ETV
Program used data from EPA's 2000 Clean
Watersheds Needs Survey (U.S. EPA, 2003h,
2003i).The Clean Watersheds Needs Survey
identifies programs and projects that are
needed to address water quality or public health
problems and are eligible for funding under the
Clean Water State Revolving Fund, "Eligible
wastewater treatment needs include the capital
costs of replacement, rehabilitation, expansion,
upgrade, or process improvement of treatment
plants; construction of new treatment plants;
and construction, replacement, or rehabilitation
of individual onsite systems and decentralized
systems" (U.S. EPA, 2003i).
  To develop the market estimate, ETV queried
the Clean Watersheds Needs Survey Unit
Process Database (U.S. EPA, 2003h) to identify
facilities with plans to install new UV disinfection
technology, replace existing disinfection processes
with UV, or expand or improve their UV
disinfection capacity. Specifically, ETV selected
records with the unit processes "Ultraviolet
Disinfection" or "UV Radiation (Disinfection)"
and changes including the words "new," "increase
capacity," "replacement," "expansion," "process
improvement," or "increased level of treatment."
This query identified 309 facilities.
  The survey database does not identify whether
individual projects are associated with treatment
for discharge or for water reuse. Discharge
treatment and water reuse projects both address
water quality and public health problems. Also,
the database includes zero discharge facilities,
where any treatment needs would be associated
with water recycling, rather than discharge
treatment. Therefore, the estimate could include
facilities planning treatment either to meet
discharge requirements or enable water reuse.
  The estimate is conservative (low) because it
only includes facilities that reported planning to
add or expand UV disinfection as of 2000 as part
Environmental Technology Verification (ETV) Program
                              19

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APPENDICES
of projects eligible for funding under the Clean
Water State Revolving Fund. It does not include
projects that are not eligible for funding under the
Clean Water State Revolving Fund. It does not
include facilities that might have developed a need
for disinfection since 2000. Finally, it does not
include facilities that might have changed their
decision about which disinfection technology to
apply since 2000. Expanding the query to include
all types of disinfection identifies approximately
4,800 facilities with plans to install, replace,
improve, or expand disinfection.
   Water Reuse Market Estimate
To estimate the market specifically for water
reuse applications, the ETV Program used data
for two states: Florida (Florida Department of
Environmental Protection, 2005) and California
(U.S. Bureau of Reclamation, 2002). The ETV
Program developed the following estimates of the
market for water reuse in each state:

* Florida: As of 2004, Florida had a total of
    100 domestic wastewater treatment facilities
   with permitted capacities greater than 0.1
   million gallons per day (MGD) that did not
   provide reuse of any kind. Of these facilities,
   68 were located in water caution resources
   areas (Florida Department of Environmental
   Protection, 2005). As discussed in Section
   3.4.1, Florida requires water reuse in these
   areas, so these 68 facilities might need
   to implement water reuse in the future.
   Florida requires disinfection for most reuse
   applications (U.S. EPA and U.S. AID, 2004).
   Therefore, these 68 facilities would need to
   apply technologies like the ETV-verified
   UV technologies to enable water reuse.
   Accordingly, the ETV Program assumed these
   68 facilities would be the most likely market
   for the verified technologies for water reuse
   applications in Florida.
*  California: As discussed in Section 3.4.1,
   California has a goal to increase water
   recycling to 1 million acre-feet per year by
   2010. To assist in meeting this goal, the
    Southern California Water Reclamation and
    Reuse Study (U.S. Bureau of Reclamation,
    2002) identified 34 water reuse projects in
    southern California for implementation by
    2010. These projects include the addition
    or expansion of treatment capacity at 46
    wastewater treatment facilities.66 California
    regulations require disinfection for most reuse
    applications (U.S. EPA and U.S. AID, 2004).
    Therefore, these 46 facilities might need
    to add disinfection or expand disinfection
    to provide the additional capacity, using
    technologies like the ETV-verified UV
    technologies. Accordingly, the ETV Program
    assumed these 46 facilities would be the most
    likely market for the verified technologies for
    water reuse applications in California.
    Based on these data, the ETV Program
estimated the market for the verified technologies
in reuse applications would be  114 facilities (68 in
Florida and 46 in California).
    This estimate is conservative (low) because it
only includes facilities in Florida and California.
Also, the estimate for each state is individually
conservative (low). The Florida estimate only
includes facilities in water resource caution areas.
The California estimate only includes facilities in
southern California that were identified as part
of the short-term implementation plan in U.S.
Bureau of Reclamation (2002).
    These facilities are likely in addition to the
309 facilities identified in the Clean Watersheds
Needs Survey, because the 309 facilities  in the
general market estimate include no facilities in
California and only one facility in Florida. There
is potential overlap, however, between the water
reuse market estimate and the discharge-related
market estimate, as discussed below.
    ETV also estimated the quantity of water
that could be recycled by facilities in the water
reuse market estimate. The Florida Department
of Environmental Protection (2005) reported
that the 468 facilities with current reuse have
a total capacity of 1,273 MGD, for an average
of approximately 2.7 MGD per facility. ETV
assumed that new facilities adding UV would
have similar capacity to the existing facilities.
The capacity increase from the 46 facilities
in California adding or expanding treatment
66 Based on review of Appendix C of U.S. Bureau of Reclamation (2002).
 120
   Environmental Technology Verification (ETV) Program

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                                                                                          APPENDICES
capacity as part of water reuse projects would
be approximately 375 MGD, for an average of
approximately 8.1 MGD per facility.67 The ETV
Program used these averages to estimate the reuse
capacities shown in Exhibit 3.4-5.
  Discharge-related Market Estimate
The discharge-related market estimate is limited
to facilities that would have to implement
additional or new treatment to comply with the
EPA's 2005 water quality standards for coastal and
Great Lakes recreation waters. In promulgating
the new standards, EPA estimated there were
approximately 90 such facilities (69 FR 67218).
In estimating the cost of the new standards, EPA
assumed that affected facilities would upgrade or
adjust existing chlorination treatment processes
to comply with effluent limitations resulting from
the new standards (U.S.  EPA, 2004d; 69 FR
67218). These facilities,  however, also could apply
the ETV-verified UV disinfection technologies,
particularly if they do not have existing
chlorination processes, their chlorination facilities
are  reaching the end of their useful life, or they
wish to benefit from the relative advantages of
UV technology over chemical processes, such
as operating cost savings and reduced space
requirements. Accordingly, ETV used the EPA
estimate of 90 facilities as the market specifically
for  meeting discharge requirements.
   This estimate is a conservative (low) estimate
of the total number of facilities that could
apply the verified technologies to comply with
regulatory discharge requirements. Additional
facilities (e.g., those that do not discharge to the
Great Lakes or ocean waters) could apply the
technologies to comply with other current or
potential future state and federal standards for
water quality and wastewater discharges other
than the new 2005 standards.
   These facilities are likely to be in addition
to those in the general market estimate, since
the new standards were proposed in 2004 and
finalized in 2005, after the 2000 needs survey.
There could, however, be some overlap, if facilities
anticipated the need to comply with the new
standards. The Clean Watersheds Needs Survey
includes both short-term and long-term needs.
Communities reporting needs in the survey
generally plan and estimate their needs over a
period of 5 to 10 years, and a few states project
their needs for up to a 20-year period (U.S. EPA,
2003i). Therefore, needs in anticipation of the
2005 standards could be within the planning
horizon used for some facilities. The 309
facilities in the general market estimate include
approximately 40 facilities in states subject to the
2005 standards.
   Also, there could be some overlap between the
water reuse market estimate  and the discharge-
related market estimate because facilities in
Florida and California are subject to the 2005
standards.
67 Based on review of Appendix C of U.S. Bureau of Reclamation (2002).
Environmental Technology Verification (ETV) Program
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