ICR SS Protozoan Data Site-by-Site: A Picture of Cryptosporidium and
Giardia in U.S. Surface Water
Jerry E. Ongerth*
Civil, Mining, & Environmental Engineering, University of Wollongong, Wollongong, New South Wales 2522, Australia
* S Supporting Information
ABSTRACT: The U.S. Environmental Protection Agency (USEPA)
Information Collection Rule Supplemental Survey (ICR SS) required
analysis of Cryptosporidium and Giardia in 10 L surface water samples
twice a week for a year by USEPA Method 1623 at 80 representative U.S.
public water systems (PWS). The resulting data are examined site-by-site
in relation to objectives of the Federal drinking water regulation, The
Long-Term (2) Enhanced Surface Water Treatment Rule (LT2),
currently under formal 6-year review by the USEPA. The data describe Cryptosporidium and Giardia in watersheds nation-
wide over a single annual cycle. Due to limited recovery efficiency measurement results are not fully quantified. In the required
sample volumes of 10 L no Cryptosporidium were found in 86% of samples and no Giardia were found in 67% of samples. Yet,
organisms were found in enough samples at 34 of 80 sites to detail a specrtum of occurrence and variability for both organisms.
The data are shown to describe indivudual site risk essential for guidance of watershed and water treatment management by
PWSs. The span of median occurrence for both organisms was about 2 orders of magnitude above the limit of detection (LD),
ca. 0.05 raw no’s/L for Cryptosporidium and ca. 0.10 raw no’s/L for Giardia. Data analysis illustrates key features of
Cryptosporidium and Giardia in surface water: presence is continuous not intermittent; zeros indicate presence below the LD;
occurrence level and variations depend on watershed sources; risk depends on both magnitude and variability of concentration;
accurate estimation of risk requires routine measurement of recovery efficiency and calculation of concentration. The data and
analysis illustrate features of Cryptosporidium and Giardia occurrence in surface water relevant to their effective regulation for
public health protection.
1. INTRODUCTION
The waterborne protozoan pathogens Cryptosporidium and
Giardia are the subject of Federal drinking water regulation in
the U.S., the Long-term 2 Enhanced Surface Water Treatment
Rule (LT2),
1
including formal Federal requirement for data
collection, the Information Collection Rule (ICR).
2
Data on
Cryptosporidium and Giardia occurrence in representative
surface water sources used by public water systems (PWS’s)
across the U.S. were produced in an addition to the
Information Collection Rule called the Supplemental Survey
(ICR SS).
2
Site-by-site analysis of this unique and extensive
data set is used to raise timely issues relevant to drinking water
regulation in the U.S. Significant work was done by the U.S.
Environmental Protection Agency (USEPA) and contractors
using data from the ICR and the ICR SS in developing and
finalizing provisions of LT2.
1
However, in generalizing the
negative-result-dominated data for the purpose of formulating
monitoring requirements for LT2, implications of the data for
each PWS and their individual sampling sites were not
thoroughly explored.
3
The focus of the analysis in this paper
is the ICR SS individual site data and their implications. In
reviewing these data along with recently published analysis of
the LT2 data some fundamental issues regarding the
formulation of the Surface Water Treatment Rule are raised.
The critical issue addressed by LT2 and to which the
Cryptosporidium (and Giardia) monitoring of both the ICR SS
and LT2 were directed is to identify the relative risk associated
with these organisms to surface water-using PWS’s.
4
The rule
includes risk management in four categories or “BINs” based on
LT2 monitoring data,
3
imposing incremental Cryptosporidium
control requirements for increasingly higher BINs. Recognizing
the principle that risk is proportional to concentration, previous
work on these organisms has established that the concentration
of Cryptosporidium and Giardia is generally proportional to the
extent and intensity of organism generating activity in the
tributary watershed.
5,6
Hence, concentrations and risk should
logically increase downstream with increasing watershed area
and activities including domestic animal raising and human
population. An overriding shortcoming of the ICR SS data is
that recovery efficiencies were not measured nor applied to
calculate concentrations from the raw numbers of organisms
found.
The concentrations of Cryptosporidium and Giardia in surface
water in the U.S. are of particular importance in 2013. This is
due to the LT2 requirement for a second round of
Cryptosporidium monitoring by the same PWS’s beginning in
2016.
1
In addition the LT2 regulation is in the midst of a
Received: June 24, 2013
Revised: August 13, 2013
Accepted: August 14, 2013
Published: August 14, 2013
Policy Analysis
pubs.acs.org/est
© 2013 American Chemical Society 10145 dx.doi.org/10.1021/es4027503 | Environ. Sci. Technol. 2013, 47, 10145-10154