stage 2 long term enhanced surface water treatment rule and

Enprotec/Hibbs & Todd

402 Cedar; Abilene TX 79601

325.698.5560 eht.com

Stage 2 Long Term Enhanced Surface Water Treatment Rule and

Stage 2 Disinfection Byproduct Rule

Scott Hibbs, P.E & Dave BakerOctober 5, 2006

2

Workshop Objective

Discuss what the Stage 2 rules cover

Discuss how Stage 2 Rules will affect your system

Discuss what you can do now to prepare for the coming Stage 2 changes

3

Workshop Outline Overview of Stage 2 Long Term Enhanced Surface Water

Treatment Rule (LT2) What does it do? Who does it do it to? When does it do it? What are the potential effects of the rule? How do you prepare now?

Overview of Stage 2 Disinfection Byproduct Rule (DBP2) What does it do? Who does it do it to? When does it do it? What are the potential effects of the rule? How do you prepare now?

4

Stage 2 Overview

LT2 DBP2Where

sampled? Raw water before treatment Treated water in the distribution system

Who sampled? Water treaters All PWSs that have distribution systems

What sampled?

CryptosporidiumE.Coli

Turbidity

TTHM and HAA5

When does preliminary

sampling start?

Group 1-Oct ‘06Group 2-Apr ‘07Group 3-Apr ‘08

Group 4-Oct ‘08 (E.coli) Group 4-Apr ‘10 (Crypto)

Group 1-Oct ‘06Group 2-Apr ‘07Group 3-Apr ‘07Group 4-Oct ‘08

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Implementation by Group

Group Number PopulationGroup 1 100,000 or moreGroup 2 50,000 – 99,999Group 3 10,000 – 49,999Group 4 Less than 10,000

Implementation schedule for Stage 2 rules are based on population of the largest system in combined distribution system

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Combined Distribution System

All systems in a combined distribution system must comply with Stage 2 DBPR requirements on the same schedule

Compliance date is based on the population of the largest system in the combined distribution system

Largest system is not necessarily the water seller

7

Definitions from Federal Register

Combined distribution system: The interconnected distribution system consisting of the

distribution systems of wholesale systems and of the consecutive systems that receive finished water from those wholesale system(s). 40 CFR 141.2

Consecutive system: A public water system that buys or otherwise receives

some or all of its finished water from one or more wholesale systems for at least 60 days per year. 40 CFR 141.2

8

Both LT2 and DBP2 require preliminary sampling programs before ultimate treatment compliance (LT2) or compliance monitoring (DBP2) is determined

Both LT2 and DBP2 require sample plans to be submitted prior to starting the sampling programs

System Monitoring Plans will need to be updated to incorporate new sampling programs

LT2 & DBP2 Implementation

9

LT2 & DBP2 Schedules Deadlines for sample plan submissions are

not the same for LT2 and DBP2 rules

SystemSize

LT2 Sample Plan Submission

DBP2 Sample Plan Submission

More than 100,000 July 2006 October 2006

50,000-100,000 January 2007 April 200710,000-50,000 January 2008 October 2007

Less than 10,000 July 2008 (E.coli)April 2008

Less than 10,000 January 2010 (Cryptosporidium)

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LT2 & DBP2 Schedules Deadlines for ultimate compliance with additional treatment needs identified

through LT2 raw water sampling and compliance monitoring at the new sampling sites identified through initial distribution system evaluations as part of DBP2 are the same

System SizeCompliance with Additional Treatment Requirements

(LT2)

Compliance Monitoring at New Sites

(DBP2)

More than 100,000 April 2012 April 2012

50,000-99,999 October 2012 October 2012

10,000-49,999 October 2013 October 2013

Less than 10,000 October 2014 October 2014

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Stage 2 Long Term Enhanced Surface Water Treatment Rule

LT2

12

LT2- Implementation

LT2 in Texas will largely be an EPA implemented program for systems serving more than 10,000 users

LT2 will be a TCEQ implemented program for systems serving fewer than 10,000 users

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LT2- Implementation

For systems serving more than 10,000 users data processing will be handled through the Internet and EPA’s Central Data Exchange (CDX)

14

LT2- Objectives

The purpose of LT2 is to reduce illness linked with Cryptosporidium and other pathogenic microorganisms in drinking water

Identifies systems that are at risk by identifying those with Cryptosporidium in their water sources

Timed to coincide with the DBP2 rule implementation to ensure that systems maintain microbial protection as they take steps to decrease the formation of disinfection byproducts

15

LT2- Applicability

LT2 applies to systems that treat surface water or ground water under the influence of surface water

Only the initial water treater must sample to determine if Cryptosporidium is present and then treat to higher log if Cryptosporidium concentration results in higher bin classification

Does not apply to groundwater systems, systems that purchase water or systems that already provide 5.5 log Cryptosporidium removal

16

LT2- Long Term Impacts

Current regulations require filtered water systems to reduce source water Cryptosporidium levels by 99% (2-log)

LT2 regulations will require up to an additional 2.5-log Cryptosporidium inactivation/removal (up to 4.5-log)

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LT2- Log Removal/Inactivation

1 log removal/inactivation = remove 90% 2-log removal/inactivation = remove 99% 3-log removal/inactivation = remove 99.9% 4-log removal/inactivation = remove 99.99% 4.5-log removal/inactivation = remove 99.9945%

Log rem/inact = Log (initial concentration / final concentration)

Log rem/inact = Log (11,245 per 100 ml / 8 per 100 ml)

Log rem/inact = Log (1405.625) = 3.1

18

LT2- Long Term Impacts Filtered water systems will be classified into one

of 4 treatment categories (bins) based on the results of the raw water monitoring

The lowest bin carries no additional treatment requirements

The higher bins require an additional 1.0-2.5 log removal or inactivation of Cryptosporidium

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LT2- Bin Classifications

Bin Average CryptosporidiumConcentration

Additional Treatment Required

1 Less than 0.075 oocysts/L or serving less than 10,000 and not required to monitorCryptosporidium

No additional treatment required

2 More than 0.075 but less than 1.0 oocysts/L

1-Log additional treatment required for conventional plants

3 More than 1.0 but less than 3.0 oocysts/L

2-Log additional treatment required for conventional plants

4 More than 3.0 oocysts/L 2.5-Log additional treatment required for conventional plants

20

LT2- Raw Water Sampling

Must undertake raw water microbial monitoring for a period of 1 or 2 years based on population served to determine treatment requirements

Larger systems will undertake an initial 2-year Cryptosporidiummonitoring program under which 24-48 samples are collected per raw water source

To reduce monitoring costs small filtered water systems (serving fewer than 10,000 users) will first monitor for E. coli and will then only monitor for Cryptosporidium if E. coli levels exceed the triggering level of 10 organisms/100 ml

The average of the sample results will determine which bin the system is assigned to and how much (if any) additional Cryptosporidium log-inactivation/removal will be required for the system

21

Cryptosporidium sample averaging for systems serving more than 10,000 users

Requirement is to at least collect 24 samples

If collect 24-47 samples then highest average of 12 consecutive months is used to define the bin classification (looks at the peaks)

If collect more than 47 samples then average of all samples is used to define bin classification (shaves the peaks)

If collect more than 47 samples, chance of being placed in higher bin is about 4 times less


22

Location of sample collection

Raw water before any chemical addition

Before backwash or recycle streams are returned

Under normal operating conditions

Regs make provisions how to sample multiple sources


23

LT2- Raw Water Sampling Type and duration of sampling is based on number of users served

If system serves more than 10,000 users

Cryptosporidium, E.coli and turbidity in each raw water source minimum of once per month for 24-months (minimum of 24 samples processed to get highest consecutive 12-month average)

Two options for frequency

Once per month – highest 12 month running annual average used for bin determination

Twice per month or more frequent – average of all 48 samples used for bin determination – option chosen by Austin Water Utility

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If system serves fewer than 10,000 users

E. coli and turbidity in each raw water source twice per month for 12-months (24 samples total in final average)

If measured concentration of E.coli in annual average exceeds 10 organisms/100 mL (lakes and reservoirs) or 50 organisms/100 mL (flowing river or stream)

Then system must complete full Cryptosporidium sample program at 2 samples/month for 1 year


25

It would be a good idea to conduct some preliminary sampling now

Will give an indication of concentration of organisms in the raw water

Will help give an idea of how many Cryptosporidium samples you will want to collect (24 vs. 48)

Will also give a preliminary indication of which bin you can expect to be placed into

Helps perfect your sampling and handling procedures


26

Multiple sources can be sampled different ways

Collect from a blended tap prior to any treatment

Volume weighted sample Composited blend of all sources Pay to ship and analyze 1 sample 1 sample and 1 result

Source weighted sample Multiple samples sent to lab separately Pay to ship and analyze multiple samples Multiple samples and multiple results used to get calculated

weighted result


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Must measure turbidity in the raw water source at the time the Cryptosporidium or E.coli sample is collected for LT2 sampling

Acceptable methods include Standard Methods 2130B…Nephelometric Great Lakes Instruments Method 2 EPA Method 180.1


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Samples must be collected within 2 days before or after of the dates indicated in the prepared and approved sample schedule

If extreme conditions are present that present a danger to the sampler then the system samples as close to the sample day as possible and submits explanation to the State on day samples are submitted

If problems arise with the submitted sample then the system must resample within 21 days and submits explanation to the State on day resamples are submitted


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The change in raw water sampling will require that you update your system monitoring plan

Consider that you’ll be adding: Raw water Cryptosporidium and E.coli monitoring Raw water turbidity monitoring on the day/s that raw water

microbial samples are collected Additional treated water sampling described later


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Cryptosporidium (EPA method 1622/1623*)

10 liters of raw water sample (for each source) shipped to the lab or

10 liters raw water sample filtered on-site and filter sent to lab

Matrix sample for every 20 Cryptosporidium samples

Note: Method 1623 includes Giardia enumeration

LT2- Crypto Analysis Method

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At present (September 12, 2006) 44 labs nationwide have been approved by EPA to analyze for Cryptosporidium

None have been approved in Texas

Lab availability for Cryptosporidium is limited

Look at both types of sampling possibilities…filtering vs. sending 10 Liters of sample

LT2- Crypto Analysis Method

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LT2- Cost of Crypto Analysis

Cost of analysis runs about $500 per sample plus shipping

Matrix sample must be run initially and every 20 samples thereafter; Minimum of 3 matrix samples

Cost of matrix sample is about $500

Overall lab cost for 24 samples will run $20,000-$25,000

Overall lab cost for 48 samples will run $40,000-$45,000

Will want to budget for Cryptosporidium testing

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Description Cost Per Number Total

Cryptosporidium and Giardia enumeration via EPA method 1623. Includes 1 filter. Lab will accept 10 liters of sample or 1 filter shipped directly to the lab. Does not include shipping charges.

$495.00 / sample 24 $11,880

Sampling Kit; includes insulated cooler, cooler packs, tubing, flow regulator, connections, and flow meter.

$50/kit 24 $1,200

Shipping cost via overnight carrier $50 / sample 24 $1,200

Matrix Spike analysis (Required initially and every 20 samples thereafter) $520 3 $1,560

Additional filters and sample processing (in case of highly turbid source waters that cause clogging) Max 1 per sampling event

$450 12 $5,400

Analysis of additional sub-samples as per method requirement (max 3 per sampling event). This occurs if pellet volumes exceed 0.5 ml as is the case in highly turbid systems

$175 12 $2,100

Total $23,340

Note: Costs provided by BCS of North Florida, Inc. 4641 NW 6th St. Suite C, Gainesville, FL 32609 phone: 352-377-9272

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Description Cost Per Number TotalCryptosporidium and Giardia enumeration via

EPA method 1623. Includes 1 filter. Lab will accept 10 liters of sample or 1 filter shipped directly to the lab. Does not include shipping charges.

$495.00 / sample 48 $23,760

Sampling Kit; includes insulated cooler, cooler packs, tubing, flow regulator, connections, and flow meter.

$50/kit 48 $2,400

Shipping cost via overnight carrier $50 / sample 48 $2,400

Matrix Spike analysis (Required initially and every 20 samples thereafter) $520 4 $2,080

Additional filters and sample processing (in case of highly turbid source waters that cause clogging) Max 1 per sampling event

$450 24 $10,080

Analysis of additional sub-samples as per method requirement (max 3 per sampling event). This occurs if pellet volumes exceed 0.5 ml as is the case in highly turbid systems

$175 24 $4,200

Total $45,640

Note: Costs provided by BCS of North Florida, Inc. 4641 NW 6th St. Suite C, Gainesville, FL 32609 phone: 352-377-9272

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LT2-Crypto Monitoring Decisions

Sampling frequency – monthly or 2x/month?

Collect bulk water or field-filter? If field-filtering, in-house staff or contract

Sample site issues Install hose bibs or use portable pump If fixed bibs, ensure access throughout monitoring period

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LT2- Laboratory Selection

Sample capacity and turn-around-time

Pricing schedule

Overall customer service and flexibility

Shipping cost to lab

Backup lab under contract

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LT2- Examples of Sampling Programs and Results

City of Austin Filtered sample 2x per month Grandfathered data… Sampled July 2002 – June2004 Sampled first and third Tuesday of each month Bin 1 for both sources

Tarrant Regional MWD Unfiltered sample 2x per month with one exception (Lake Arlington) Grandfathered data… Sampling began 1993 Bin 1 for all sources

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Austin’s Water Sources

Lake Austin – Colorado River System Davis WTP – 120 MGD Ullrich WTP – 100 MGD

Town Lake – Colorado River System Green WTP – 42 MGD

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Austin’s Crypto Sampling Results

Green WTP Davis WTP Ullrich WTP

Number of Events 48 48 48

Positive Count 11 2 4

Range (Oocysts/L) 0.02-0.06 0.02-0.06 0.02-0.04

Average (Oocysts/L) 0.006 0.002 0.002

Bin 1 1 1

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Austin’s Total Costs of Two-Year Monitoring

~$46,000 for contracted Crypto analysis at $319 per sample

~$3,000 for in-house turbidity & E. coli testing supply costs

~$12,000 labor cost (600 man-hours) Includes: sample collection, paperwork, shipping, data

logging, in-house testing, equipment cleaning & preparation

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30 wholesale customers, 65 cities, 1.6 million population served

Primary Wholesale customers include City of Arlington City of Ft. Worth City of Mansfield Trinity River Authority

Tarrant Regional Water District

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Tarrant Regional Water District

Cryptosporidium sampling program

Dec 1993 – June 1997 – ASTM P229

July 1997 – June 1999 – ICR method

July 1999 – present – 1623 method

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TRWDReservoirs and Watersheds

NAVARROHILLHENDERSON

FREESTONE

ELLIS

KAUFMAN

VAN ZANDT

ROCKWALL

DALLASTARRANT

JOHNSON

WISEJACK

PARKER

HOOD

YOUNG

ARCHER CLAYMONTAGUE

Eagle Mountain

Benbrook

Bridgeport

Cedar Creek

Richland-Chambers

Pipeline System

Arlington

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Site pictures

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Lake Arlington* Benbrook Cedar

CreekEagle Mtn

LakeWorth

RichlandChambers

Hits 1 0 3 3 6 0

Mean/L .005 .000 .006 .010 .017 .000

BIN 1 1 1 1 1 1

* 24-month dataset all others 48-month dataset

TRWD’s Crypto Sampling Results

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Summary Crypto Monitoring Recommendations

Establish Sampling locations Apparatus setup and monitoring Weather concerns

Contact labs for availability/capacity Develop sampling schedule Decide on field filtering or bulk water collection

Filter clogging Shipping costs

Check overnight shipping schedules and times Develop bid package and select lab based on bids Have back-up lab & wording in primary contract that allows use of

backup Practice collection and shipping

67

LT2- E. coli Analysis Method Standard Methods 9223B

Colilert and Colilert-18

Standard Methods 9221B and 9221F Multiple-tube fermentation method

Standard Methods 9222B and 9222F Membrane filtration method

Other approved methods Standard Methods 9213D (mTEC agar) EPA Method 1603 (modified mTEC) EPA Method 1604 (MI medium) and M-ColiBlue24 Broth

68

LT2- E. coli Analysis Method Lab availability for E. coli sample analysis is very good…not an

issue as with Cryptosporidium labs

E. coli is analyzed at most municipal WWTPs of moderate size

Possible to conduct this in-house or at a lab relatively close by for minimal cost

Minimum of two 100-mL sterile plastic bottles…better to request two 120-mL or 250-mL bottles

Cost for E. coli analysis runs about ($35-$50 per sample) for a total LT2 sample program cost of about $1,000-$1,500

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Sample results must be reported no later than 10 days after the end of the 1st month following month of sample collection (samples collected in January are reported by March 10th)

Results are reported electronically by the lab conducting the analysis

As the water system official, you have access to the data reporting site at…

http://cdx.epa.gov

LT2- Data Entry and Reporting

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LT2- Toolbox Options

When sampling shows the need to treat to higher log removal/inactivation then the system turns to the “microbial toolbox” for additional treatment options

The toolbox consists of a range of source water management and treatment strategies to meet any additional treatment requirements

Toolbox options consist of…

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Watershed control options

Treatment options

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LT2 Toolbox

Watershed Protection

Treatment Approaches

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LT2 Toolbox


Watershed Control Program

Intake Relocation


IntakeManagement

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LT2 Toolbox



PretreatmentOptions

Improved Treatment Options

Alternative Treatment Options

InactivationOptions

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LT2 Toolbox

Watershed Protection Treatment Approaches

Watershed Control Program Pretreatment

Improved Treatment

Alternative Treatment

Inactivation

Intake Management

In-bank Filtration

Pre-Sedimentation

CFE Turbidity

IFE Turbidity

Two-stage Filtration

Lime Softening

Higher Performance

Membranes

Slow Sand

Bag/Cartridge

Ultraviolet Light

Ozone

Chlorine Dioxide

Intake Relocation

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Watershed control

Watershed control program; 0.5 log credit for implementation of state approved plan 4 key elements of a watershed control program

Delineate area of influence Identify Cryptosporidium sources Evaluation of control measures Must establish goals, schedule, staffing requirements

Maintain log removal credit by submitting annual report and completing sanitary survey every 3 years

Credit continues as long as the state-approved plan is followed

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Watershed control (continued)

New source water…Does the possibility exist to utilize alternative source?

Intake relocation or intake management…relocate intake to new location or modify depth and/or timing of intake use

No prescribed credit but possible to be placed into lower bin


78


Pretreatment alternatives

Improved treatment alternatives

Alternative treatment

Increased inactivation


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Pretreatment Alternatives

Coagulation and pre-sedimentation…addition of a new presedimentation basin…0.5 log credit when demonstrate at least 0.5-log turbidity removal; Must use coagulant and all plant flow must pass through the process

Two-stage lime softening…0.5 log credit when chemical addition and hardness precipitation occur in both stages; All plant flow must pass through both stages

Bank filtration…refers to GWUI well setback distance from SW; 25-foot setback gets 0.5 log credit; 50-foot setback gets 1.0-log credit


80

Improved Treatment Alternatives

Enhanced CFE turbidity limits 0.5-log credit if CFE is less than 0.15 NTU in at least 95% of required

readings

Enhanced IFE turbidity limits 1.0-log credit if IFE is less than 0.1 NTU in at least 95% of the max

daily readings each month and IFE is les than 0.3 NTU in 100% of the 15-minute readings

Demonstration of improved plant performance Full-scale ambient aerobic spores and pilot scale spiking studies


81

Alternative Treatment Options

Bag/cartridge filtration…addition of bag or cartridge filter process is worth additional log removal on a site specific basis pursuant to challenge study

Membrane filtration…log removal for membrane treatment is decided on a site specific basis pursuant to challenge study

Staged filters…0.5-log credit for second stage granular media filters if coagulant is used prior to first stage filters

Slow sand filters… 2.5-log credit as a secondary filtration step; 3.0-log credit as a primary filtration process


82

Chlorine dioxide Based on CT calculations (contact time, residual, baffling, temp)

Ozone Based on CT calculations (contact time, residual, baffling, temp)

UV Not currently getting CT credit for using UV Possibility exists to run challenge studies (highly involved) UV issues are evolving…would expect some standardization of

CT value for UV soon

LT2- Treatment Options

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LT2 Compliance Pathway

Draft and submit raw water sample plan

Complete 1st round of raw water sampling per sample plan

Look to microbial toolbox if added log

removal/inactivation is needed

Complete 2nd round of raw water sampling

Complete and submit bin classification report

84

LT2- Potential Violations Monitoring Violations

Failure to collect a required sample on time

Treatment Technique Violations Failure to collect required number of samples to set bin classification;

If 3 or more samples are missed, must go to 5.5-log removal Failure to report bin classification Failure to provide required treatment by compliance date Failure to provide sufficient inactivation in unfiltered systems Failure to demonstrate minimum required treatment credit Revocation of a watershed control program Failure to monitor alternative source water location point Exceeding individual filter performance limits

85

LT2- Implementation Timeline

System Size

Sample Plan

Sampling Begins

Submit Bin Class

Treatment Compliance

Resampling Begins

More than 100,000 Jul ‘06 Oct ‘06 Apr ‘09 Apr ‘12 Apr ‘15

50,000-99,999 Jan ‘07 Apr ‘07 Oct ‘09 Oct ‘12 Oct ‘15

10,000-49,999 Jan ‘08 Apr ‘08 Oct ‘10 Oct ‘13 Oct ‘16

Less than 10,000

Jul ‘08 (E.coli) Oct ‘08

Oct ’11 (2/m)Or

Oct ’12 (1/m) Oct ‘14 Oct ‘17

Less than 10,000

Jan ‘10 (Crypto)

Apr ‘10 Oct ’11 (2/m)Or

Oct ’12 (1/m)Oct ‘14 Apr ‘19

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LT2 - Steps to Take Now Begin preliminary raw water monitoring to get a feel for expected bin

classification and lab costs as well as gain practice and sort out sample sites <10,000 users…E.coli; Look for levels >10 organisms/100mL in

reservoirs and >50 organisms/100 mL in flowing If results exceed these triggers then expect to monitor for Crypto

which is expensive >10,000 users…Crypto and E.coli

Budget monies for LT2 Crypto analytical needs $15 k per year for 1/month $25 k per year for 2/month

Begin to look at upgrading your system monitoring plan

87

End of LT2

Questions…

88

Stage 2 Disinfection Byproduct Rule

DBP2

89

DBP2- Overview The purpose of DBP2 is to reduce risk related to TTHM and HAA5 in

drinking water

MCLs under Stage 2 remain the same…80 ppb TTHM and 60 ppb HAA5

DBP2 compliance monitoring will change from running annual average to locational running annual average

Most water systems that serve more than 500 users will have to evaluate and select new DBP sample sites under DBP2

This is the Initial Distribution System Evaluation or IDSE

IDSE is a means of selecting new DBP compliance monitoring sample sites to reflect high TTHM and high HAA5

90

DBP2- Applicability

Stage 2 Disinfection Byproducts Rule applies to:

Every utility that delivers water through a distribution system

Every utility that uses disinfectants other than ultraviolet light… Regardless of source water type

91

DBP2- Applicability

Unlike with LT2, DBP2 affects purchased water systems and groundwater systems

Targets systems that are at greatest risk…those with TTHM and HAA5 above 50% of MCL (40/30 ppb) by requiring those systems to complete an Initial Distribution System Evaluation (IDSE)

92

DBP2- Impacts Involves more extensive monitoring for DBPs in distribution

systems

Requires systems serving more than 500 users, regardless of water source type, to complete an IDSE

IDSE exception is given to very small systems (fewer than 500 users)

Very small systems go right into Stage 2 compliance monitoring at existing Stage 1 sites

All other systems must complete an IDSE of some type

93

Under DBP2 all systems in a combined system with wholesalers and retailers are on same compliance schedule as the largest system in the distribution network

Number of sample sites for an individual system in the combined distribution system though will still be dependent on size of the individual system

All systems will go to compliance based on locational running annual average of TTHM and HAA5 sample results at the new sample sites selected through the IDSE

Even though very small systems are exempt from completing IDSEs to select new sites, they also go to LRAA

DBP2- Impacts

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DBP1 required DBP sample collection at location in system approximating maximum residence time

Under DBP2, more attention is focused on identifying … Locations of high TTHMs Locations of high HAA5s

The IDSE process is used to identify high TTHM and HAA5 compliance monitoring sites

DBP2- Compliance Monitoring Sites

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DBP2- Details on IDSE

IDSE is a study conducted by the utility

It is intended to select new DBP compliance monitoring sites reflecting high TTHM and HAA5 in the system

Based on system specific sampling or on hydraulic modeling

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DBP2- TCEQ’s Role in the IDSE

DBP2 will be a TCEQ implemented program…TCEQ will help you through the IDSE by prompting with written correspondence

TCEQ will help with Very small system waiver (will send letter to system) 40/30 waiver (will send letter to system) IDSE sampling point identification (fill in the blank letter) IDSE reports at end of IDSE sampling DBP2 compliance monitoring sample site selection

You should anticipate how your system is going to meet IDSE needs…

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DBP2- EPA’s IDSE Tool EPA’s IDSE tool is a web-based tool to help the water system official

with IDSE process from inception to completion

Steps the user through a series of questions to identify the most appropriate IDSE approach for your system

Provides templates for IDSE Plans and Reports…TCEQ will generate these for you, but understanding the stages is a very good idea

Can submit reports on-line, but Alicia Diehl advises TCEQ will submit on your behalf

Tool is good for helping select sites…Web page address http://www.epa.gov/safewater/stage2/index.html

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IDSE Wizard will walk you through a series of questions

Will determine if you qualify for VSS waiver

If not then will determine if you qualify for 40/30 waiver

If not will determine if you have collected data for system specific study

If not, it will start you on your way to completing the IDSE standard monitoring plan

IDSE tool and IDSE wizard are very useful in setting up your IDSE and determining your IDSE compliance pathway

DBP2- EPA’s IDSE Tool

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Four ways to determine DBP2 compliance monitoring sites

Very Small System (VSS) Waiver is taken by systems that serve fewer than 500 users and system continues to sample DBP1 monitoring location/s

40/30 Waiver granted if all Stage 1 TTHM and HAA5 results were less than half the respective MCLs and there were no monitoring violations

Initial Distribution System Evaluation (IDSE) via Standard Monitoring Plan

IDSE via System Specific Study (SSS)

Let’s look at a decision making tree for site selection…

DBP2- IDSE Alternatives

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DBP2 Compliance Pathways

Do you qualify for 40/30 waiver?

IDSE via SMP

Do IDSE

IDSE via SSS

Stage 2 Compliance Monitoring

If yes If no

If noIf yes

IDSE Report

Does your system serve fewer than 500 persons?

Update Monitoring Plan to reflect new sites

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DBP2- IDSE Timeline

System Size IDSE Plan Complete IDSE Submit Report MCL Compliance at New Monitoring Sites

More than 100,000 Oct ‘06 End of Sep ‘08 Jan ‘09 Apr ‘12

50,000-99,999 Apr ‘07 End of Mar ‘09 Jul ‘09 Oct ‘12

10,000-49,999 Oct ‘07 End of Sep ‘09 Jan ‘10 Oct ‘13

Less than 10,000 Apr ‘08 End of Mar ‘10 Jul ’10 Oct ‘14

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Very Small System (VSS) Waiver

40/30 Waiver

IDSE via Standard Monitoring Plan (SMP)

IDSE via System Specific Study (SSS)

DBP2- IDSE Alternatives

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DBP2- Very Small System Waiver Very Small System (VSS) Waiver

Less than 500 customers

Must have DBP1 samples from max water age site

Must have collected all required Stage 1 DBP samples

TCEQ will notify via letter of the waiver for these systems

System official then returns the letter certifying that the system qualifies and DBP1 sample sites are then used for DBP2

Possibility exists to need to add a monitoring site (most likely high HAA5); If so, will need to update Monitoring Plan

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40/30 Waiver (low levels of TTHM and HAA5 during DBP1 monitoring)

All existing DBP1 TTHM sample results less than 40 ppb

All existing DBP1 HAA5 sample results less than 30 ppb

TCEQ to notify system via letter

System official then returns the letter certifying that the system qualifies and DBP1 sample sites used for DBP2

Possibility exists to need to add sites (most likely high HAA5); If so, will need to update Monitoring Plan

DBP2- IDSE & 40/30 Waiver

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DBP2- IDSE & 40/30 Waiver

40/30 Waiver applies to DBP1 samples collected as follows:

Group 1More than 100,000

Calendar years 2004 thru 2005

(beginning no earlier than January 2004)Group 250,000-99,999

Group 310,000-49,999

Calendar years2005 thru 2006

(beginning no earlier than January 2005)Group 4Less than 10,000

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If unable to meet VSS waiver or 40/30 waiver then will have to complete IDSE to identify the compliance monitoring sites.

Standard monitoring plan (SMP)…default approach…comparatively easy but more costly Involves identifying then sampling at multiple sites

suspected as high TTHM/HAA5 sites

System specific study…relatively complex Use system specific data and hydraulic model of

distribution system to identify new sites that are comparable or superior to sites identified through Standard Monitoring Plan approach

DBP2- IDSE Beyond the Waivers

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DBP2- SMP or SSS?

SMP is the default approach to selecting new compliance monitoring sites Involves one-year of increased distribution system monitoring to

find locations with high TTHM and HAA5 TCEQ coordinated sampling plan required TCEQ’s contractor collects samples Once the IDSE SMP is approved by TCEQ, TCEQ coordinates

sampling and information processing

SSS is the alternative approach to SMP requires calibrated model of your distribution system Requires adequate SCADA in distribution system

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Thoughts on IDSE site selection:

Preliminary site selection for IDSE monitoring - pick more than you need and then work to prove sites for inclusion on final site list for IDSE

IDSE monitoring sites - required to have specific number (see table on slides 82 and 83)

There are more IDSE monitoring sites than there are ultimate Stage 2 compliance monitoring sites

Stage 2 compliance monitoring sites ultimately selected from IDSE monitoring sites and Stage 1 compliance sites

DBP2- IDSE Site Selection

109

Required to select up to 4 types of monitoring sites for the IDSE

Near entry point Average residence time High TTHM sites High HAA5 sites

Near entry point is pretty easy…others need a little more effort to locate

The number of IDSE sites and frequency of sampling are determined by population and water source for your system…the date you must start the IDSE is determined by population of the largest system in the combined distribution system


110

Distribution system map is useful…Plot on a map

Entry point/s Sites representing average residence time Sites representing high residence time Stage 1 DBP Rule collection sites Sites or areas where disinfectant residual is typically low Storage tanks Disinfectant booster stations Problem areas


111

High TTHM formation conditions

Sites with relatively low chlorine residual

Higher water temperature and increased water age lead to higher TTHM…Common for DBPs to peak in summer months

Storage facilities increase the water age and potential for higher TTHMs… Downstream of storage facilities

Dead ends or low use areas create higher TTHMs… Generally in remote or low demand areas

Found in areas similar to historic high Stage 1 TTHM sites (unless conditions have changed since sites were selected)


112

High HAA5 formation conditions

Higher water temperature and increased water age lead to higher HAA5 May be near entry point

Found in similar areas to the historic high Stage 1 HAA5 sites (unless conditions have changed since sites were selected)

Can move around the system depending on the season HAA5 can biodegrade where biological activity is present and

disinfectant residuals are low or non-existent Where adequate chlorine residual suppresses heterotrophic bacteria

Free chlorine residual > 0.2 mg/L Chloramine (total Cl) residual > 0.5 mg/L

HAA5 sites should be at a location where disinfectant residuals are below average but still present


113

Impact of Free Cl2 Residual on HPC Growth

H ellings Tank W ater Q uality - 1998-1999

0

2000

4000

6000

8000

10000

Jan-

98

Feb-

98

Mar

-98

Mar

-98

Apr

-98

May

-98

Jun-

98

Jul-9

8

Sep-

98

Oct

-98

Nov

-98

Dec

-98

Jan-

99

Feb-

99

Mar

-99

Apr

-99

May

-99

Jun-

99

Jul-9

9

Aug

-99

Sep-

99

Oct

-99

Dec

-99

Het

erot

roph

ic B

acte

ria /

mL

0

0 .2

0.4

0.6

0.8

1

Free

Chl

orin

e m

g/L

C L2Free m g/L H P C C FU /m Ls

114

DBP2- IDSE sampling schedule

Find your peak historic month: Month of historical peak DBP levels, OR Month of highest water temperature

Set a sampling date during peak historic month

Set dates at appropriate time intervals on each side of peak historic month

Make a calendar showing sampling dates

115

DBP2- TTHM Variability by Season

Important in finding peak historic month for IDSE

116

DBP2- Suggested Sampling Protocol

Sample during morning hours - allows time for samples to be packed and shipped

Samples should be representative Collect indoor samples from the cold water line Sample bottles should contain appropriate

dechlorinating agents/preservatives Replace a lost or broken sample as soon as possible

117

DBP2- Steps to Complete IDSE via SMP1. Budget monies now to complete IDSE via SMP

For proving sample sites For actual IDSE monitoring samples

2. Prepare a draft IDSE Standard Monitoring Plan showing Number and location of all selected SMP sample sites

High TTHM High HAA5 Near entry point Average residence time

Will need to describe rationale for selection of sample sites

3. Conduct preliminary sampling/evaluation to confirm proposed sites as appropriate for IDSE sampling

4. Complete IDSE Plan (sent to you by TCEQ) based on the preliminary site ID

118

3. Obtain plan approval from TCEQ

4. TCEQ’s sample contractor will then complete TTHM/HAA5 monitoring for one year pursuant to approved IDSE plan at sites you selected

5. TCEQ will determine Stage 2 compliance monitoring sites based on results from the IDSE sampling conducted by their contractor

6. System official will confirm the Stage 2 compliance monitoring sites presented by TCEQ

7. Compliance monitoring begins at the new sites

DBP2- Steps to Complete IDSE via SMP

119

Number of required IDSE Standard Monitoring Plan sample sites is dependent upon water type and population

Required number of IDSE sites to monitor via a Standard Monitoring Plan is as follows…

DBP2- IDSE via SMP

120

IDSE Standard Monitoring SW and GWUDI Systems

Source Water Type

System Size (Population Served)

# of Monitoring

Periods (Frequency

of Sampling)

IDSE SMP Distribution System Monitoring Locations

Number of Sites

Near Entry Point

Average Residence

Time

High TTHM

High HAA5

Surface Water

& GWUDI

<500 consecutive systems

One (during peak

historical month)

2 1 1

< 500 non-consecutive 2 - - 1 1

500-3,300 consecutive systems Four (every

90 days)

2 1 - 1

500-3,300 non-consecutive

2 - - 1 1

3,301-9,999

Six (every 60

days)

4 - 1 2 1

10,000-49,999 8 1 2 3 2

50,000-249,999 16 3 4 5 4

250,000-999,999 24 4 6 8 6

1,000,000-4,999,999 32 6 8 10 8

≥ 5,000,000 40 8 10 12 10

121

IDSE Standard Monitoring for Ground Water Systems

Source Water Type

System Size (Population

Served)

# of Monitoring Periods

(Frequency of Sampling)

IDSE SMP Distribution System Monitoring Locations

Number of Sites

Near Entry Point

Average Residence

Time

High TTHM

High HAA5

Ground Water

< 500 consecutive systems

One (during peak

historical month)

2 1 1

<500 non-consecutive

Four (every 90 days)

2 1 1

500-9,999 2 1 1

10,000-99,999 6 1 1 2 2

100,000-499,999 8 1 1 3 3

≥ 500,000 12 2 2 4 4

122

IDSE samples will be collected by TCEQ’s sample contractor same as Stage 1 DBP samples are collected

Data from IDSE samples will flow through TCEQ to EPA…water system will not have to transfer IDSE information…(Alicia Diehl)

TCEQ will arrange for and pay for collection of the samples through its sample collection contract

Water system pays for analysis of the samples analyzed by Dept of State Health Services Lower Colorado River Authority

Total cost for IDSE via SMP sampling through TCEQ is as follows...

DBP2- IDSE via SMP

123

IDSE Standard Monitoring Cost for SW and GWUDI Systems

Source Water Type System Size (Population Served)

Total Cost(Budget for This to Complete IDSE

via SMP; Budget extra for any preliminary site proving)

Surface Water &

GWUDI

<500 consecutive systems $574

< 500 non-consecutive $574

500-3,300 consecutive systems $2,296

500-3,300 non-consecutive $2,296

3,301-9,999 $6,888

10,000-49,999 $13,776

50,000-249,999 $27,552

250,000-999,999 $41,328

1,000,000-4,999,999 $55,104

≥ 5,000,000 $68,880

124

IDSE Standard Monitoring Cost for Ground Water Systems

Source Water Type System Size (Population Served)

Total Cost(Budget for This to

Complete IDSE via SMP; Budget extra for any

preliminary site proving)

Ground Water

< 500 and is consecutive system $574

<500 and is non-consecutive $574

500-9,999 $2,296

10,000-99,999 $6,888

100,000-499,999 $9,184

≥ 500,000 $13,776

125

DBP2- IDSE Report Based on SMP

• TCEQ will use the Stage 1 compliance monitoring data and the IDSE SMP data to calculate LRAA for each DBP sample site

• TCEQ will select sites with highest TTHM and HAA5 LRAA to serve as Stage 2 compliance monitoring locations

• TCEQ will send the IDSE report to the water system official for verification and certification of Stage 2 compliance monitoring sites

• Water system must then update its Monitoring Plan to reflect new compliance monitoring sites…if serve >3,300 users, must submit the updated MP to TCEQ for approval

126

DBP2- IDSE SMP Report

Examples in IDSE Guidance Manual and 7-page electronic IDSE Report Form

Locations of Stage 2 compliance sites and why they were selected All IDSE and Stage 1 data in tabular format Schematic of distribution system, population served, system type Original IDSE monitoring plan and explanation of deviations Recommended Stage 2 locations and sample timing (i.e., include

peak historical month) Justification for Stage 2 site selection

127

Why consider a System Specific Study (SSS)

IDSE SMP entails extensive sampling effort

8 samples every 60 days (for 10,000 – 50,000 system)

TTHM and HAA5 analytical cost ~ $14,000 (for 10,000 – 50,000 system)

Additional costs for “proving” samples

Utility may benefit from tools developed in system specific study

DBP2- IDSE- System Specific Study

128

Potential benefits of SSS approach

No need to perform SMP…potential $ savings

Improvements in system operation Tank operations Water age management

“What if” scenarios possible

Multiple side benefits of having a well-calibrated hydraulic model

DBP2- IDSE SSS

129

DBP2- IDSE- SMP vs. SSS

Key Element SMP SSS

IDSE Plan required Yes Yes

IDSE Plan approval Yes Yes

Analytical laboratory Yes Yes

Model required No Yes

Analytical cost High Low-Moderate

Modeling cost None High

Staff time Low High

IDSE report required Yes Yes

130

A calibrated hydraulic model intended for detailed distribution system design or operational studies design is likely to be adequate

A well-calibrated water quality model is also likely to be adequate

In any case, the model must be an extended period simulation and must be calibrated for system conditions during peak month TTHM formation

Model must also be calibrated for current system configuration in the distribution system (new growth, new users)

DBP2- IDSE SSS

131

IDSE- System Specific Study using an hydraulic model of the system

Intended to allow systems that have models to use their technical resources to perform the IDSE

For most systems though the cost of developing a model from scratch for the IDSE-SSS will outweigh the cost of IDSE-SMP

If the model will be used for other purposes after completion of the SSS such as optimizing system operations and prioritizing capital improvements then cost of model development may be justified

To be used for IDSE-SSS, model must meet minimum requirements

DBP2- IDSE SSS

132

Model requirements

Required hydraulic model for SSS is more comprehensive than those typically used for long range capital improvements program analysis of transmission capacity

A calibrated hydraulic model intended for detailed distribution system design or operational studies design is likely to be adequate

A well-calibrated water quality model is also likely to be adequate

In any case, the model must be an extended period simulation and must be calibrated for peak month TTHM formation

Model must also be calibrated for current system configuration in the distribution system (new growth, new users)

DBP2- IDSE SSS

133

Model requirements (continued)

Most models don’t include every pipe in the distribution system (skeletonization)

To be used for the SSS the model will be need less skeletonized >50% of pipe length in distribution system >75% of pipe volume in the distribution system All 12-inch and larger pipes All major facilities and controls See exhibit 6.1 in IDSE Guidance Manual for minimum

model requirements

DBP2- IDSE SSS

134

SSS requirements

Calibrate hydraulic model of distribution system

Model validation during Peak Historic Month TTHM formation

Water age modeling

One round of sampling

Establish new compliance monitoring sites

Develop IDSE – SSS Report

DBP2- IDSE SSS

135

Hydraulic model development

Assign demands Half of nodes All end nodes All water uses Requires good water billing information, land use, etc.

Diurnal patterns Requires information on rate of consumption over time

DBP2- IDSE SSS

136

Hydraulic model development System operation…Requires records of operation such as

SCADA Tank levels Pump operation Valve settings Pressure/flows

Need historic DBP and temperature records for peak historic month

DBP2- IDSE SSS

137

Hydraulic model calibration Steady-state calibration using SCADA

Verify spatial distribution of demands Verify model infrastructure (fire flow tests)

Dynamic calibration using SCADA Verify temporal demand distribution Verify operational settings

Level of calibration must be sufficient for intended use (IDSE guidance manual)

IDSE report must justify the level of calibration

DBP2- IDSE SSS

138

Use calibrated model to select sites

Use model to predict water age Chlorine residual data and residence time are compared

Select multiple sites for one round of sampling during controlling month of high TTHM formation

Use results to develop relationship between water age and DBP concentration

DBP2- IDSE SSS

139

Hydraulic model SSS Report requirements

24-hour time series graph of residence time for each Stage 2 compliance location

Explanation of any deviations from SSS Plan

All analytical and modeling results used to select sites Demonstrate that SSS characterized TTHM and HAA5 levels

throughout entire distribution system

Recommendations and justifications for Stage 2 compliance monitoring locations and timing

DBP2- IDSE SSS

140

First Quarter Second Quarter Third Quarter Fourth Quarter

{

Average of AllSamples

{Average of All

Samples

{Average of All

Samples

{

Average of All Samples

Running Annual Average of Quarterly Averages

Must Meet MCLs

DBP1- Running Annual Average

141

First Quarter Second Quarter Third Quarter Fourth Quarter

1st Quarter2nd Quarter

3rd Quarter

4th Quarter

{

LRAA 1 Must be Below MCLs

1st Quarter2nd Quarter

3rd Quarter

4th Quarter

{

LRAA 2 Must be Below MCLs

DBP2- Locational Running Annual Average

142

DBP2- RAA vs. LRAA

Quarter Site 1 Site 2 Site 3 Site 4

1 56 69 78 48

2 59 72 89 57

3 68 81 85 65

4 65 74 77 46

Comparison of compliance determination under Stage 1 DBP to compliance determination under Stage 2 DBP

63

69

75

66

68LRAA 62 74 82 54

Qtr Avg

TTHM (ppb)

RAA

143

DBP2- RAA vs. LRAA

Under Stage 1 DBPR, with a RAA of 68 ppb TTHM, this system was in compliance with this set of TTHM sample results

Under Stage 2 DBPR, with a LRAA at Site 3 of 82 ppb, this system was out of compliance using the very same set of TTHM sample results

The change from RAA to LRAA will make a difference for systems currently close to DBP noncompliance

144

DBP2-Operational Evaluation

Rule requires systems that exceed operational evaluation levels (referred to significant excursions) to evaluate system operational practices and identify opportunities to reduce DBP levels

Operational evaluation levels are calculated for each DBP monitoring location using the latest three quarters of results as the sum of the two previous quarters sample results at that location plus two times the latest sample result at that location (Q1 + Q2 + 2Q3)/4

If the result of the operational evaluation exceeds the respective MCL then the system must submit Operational Evaluation Report within 90 days of getting sample results that lead to determination of operational evaluation level exceedance

145

Operational Evaluation Report must contain an examination of the system treatment and distribution operational practices including Changes in source or source water quality Changes in storage tank operation and efforts to minimize

excess storage capacity Other steps to minimize future operational evaluation

exceedances Information about causes (where available) of current

operational evaluation level exceedance Water quality data Plant performance data Distribution system anomalies


146

“Significant exceedance” in preliminary guidance documents was replaced by “operational evaluation levels”


147

DBP2- Possible Violations

Failure to submit IDSE plan Failure to collect compliance monitoring samples Exceeding TTHM/HAA5 LRAA MCLs (80/60)

148

DBP2- Compliance MonitoringSystem

SizeMonitoring Frequency

Total Sites

High TTHM

High HAA5

Existing Sites

500 or less Yearly 2 1 1 NA

500-3,300 Quarterly 2 1 1 NA

3,301-9,900 Quarterly 2 1 1 NA

10,000-49,999 Quarterly 4 2 1 1

50,000-249,999 Quarterly 8 3 3 2250,000-999,999 Quarterly 12 5 4 3

1,000,000-4,999,999 Quarterly 16 6 6 4More than 5,000,000 Quarterly 20 8 7 5

149

DBP2- Steps to Take Now

Begin distribution system profile monitoring to get a feel for expected TTHM and HAA5 profile in distribution system

Pick your distribution IDSE sites in advance through results gained from profiling

Budget monies for DBP2 analytical needs Based on population served

Begin to look at upgrading your system monitoring plan

150

Stage 2 EPA Guidance Manuals

Rules and guidance manuals are available online at

http://www.epa.gov/safewater/disinfection/index.html

LT2 The Rule from CFR DBP2 The Rule from CFR Initial Distribution System Evaluation Guidance Manual IDSE Guidance for Systems Serving < 10,000 Operational Evaluation Guidance Manual Stage 2 DBPR Implementation Guidance Stage 2 / LT2 Simultaneous Compliance Guidance Stage 2 DBPR Small System Compliance Guidance Consecutive System Compliance Guidance Manual

151

Questions…

Thanks for coming…

stage 2 long term enhanced surface water treatment rule and

Documents