Presentation on theme: "Systems Working Together to Comply with New LT2/Stage 2 M/DBPRs KY & TN Wholesale."— Presentation transcript:
1Systems Working Together to Comply with New LT2/Stage 2 M/DBPRs KY & TN Wholesale and Consecutive System Case Study Scenarios*Jan C. RouttJan Routt & Associates, LLCKY-TN Joint Water Professionals ConferenceChattanooga, TennesseeJuly 10, 2006*adapted from original presentation, photos omitted for web posting.
2Implementation Schedule * WE ARE HEREImplementation Schedule *20062007200820092010201120122013201420152016Crypto monitoringTreatmentInstallationPossible Extension1ReviewsubmissionIDSEComplianceCrypto monitoringTreatmentInstallationPossibleExtension2ReviewsubmissionIDSEComplianceCrypto monitoringTreatmentInstallationPossible Extension3ReviewsubmissionIDSEComplianceCompliance(if Crypto Monitoring)E. coliPossibleExtensionCrypto monitoring4ReviewsubmissionIDSETreatment InstallationCompliance(if no Crypto Monitoring)20062007200820092010201120122013201420152016LT2 Plan or bin classification dueStage 2 IDSE Plan or report due* Includes associated consecutive systems
3New Definitions40 CFR 141.2Combined distribution system (CDS) – Interconnected distribution system consisting of the distribution system of wholesale systems and consecutive systems that receive finished water.Consecutive system – PWS that receives some or all of its finished water from one or more wholesale systems.Wholesale system – PWS that treats source water as necessary to produce finished water and then delivers some or all of that finished water to another PWS.Finished water – Water introduced into the distribution system of a PWS intended for distribution and consumption without further treatment, except as necessary to maintain water quality in the distribution system.Combined distribution system (CDS): Interconnected distribution system consisting of the distribution systems of wholesale systems and consecutive systems that receive finished water.Consecutive system: PWS that receives some or all of its finished water from one or more wholesale systems.Dual sample set: Set of two samples collected at the same time and location, with one sample analyzed for TTHM and the other analyzed for HAA5.Finished water: Water introduced into the distribution system of a PWS intended for distribution and consumption without further treatment, except as necessary to maintain water quality in the distribution system.GAC10: Granular activated carbon filter beds with an empty-bed contact time of 10 minutes based on average daily flow and a carbon reactivation frequency of every 180 days, except that the reactivation frequency for GAC10 used as a BAT for compliance with Stage 2 DBPR MCLs under (b)(2) shall be 120 days.GAC20: granular activated carbon filter beds with an empty-bed contact time of 20 minutes based on average daily flow and a carbon reactivation frequency of every 240 days.Locational running annual average (LRAA): Average of sample analytical results for samples taken at a particular monitoring location during the previous four calendar quarters.Wholesale system: PWS that treats source water as necessary to produce finished water and then delivers some or all of that finished water to another PWS.
4Combined Distribution Systems Wholesale System100,000Wholesale andConsecutive System10,000Consecutive System50,000TreatmentPlantSystem ASystem BSystem CLT2RiverTreatmentPlantRiverLT2This is an illustration of a combined distribution system.In this example, System A sells water to System B, which in turn sells water to System C. System A is the largest system in the combined distribution system. System B has its own source and sells water to System C.For LT2 system A must comply on schedue 1 (>100K). System B serves 10k in its system and sells to system C which serves 50K population therefore, B must comply monitor its source water and implement treatment on Schedule 2 due to selling water to System C with >50K population.For Stage 2 DBPR System A complies based on the requirements for a system serving 100,000 people. But because System B purchases water from System A, System B must comply with the Stage 2 DBPR schedule based on the population of the largest system in the combined distribution system, which is System A. Even though System C does not sell water and does not have its own source, it is still required to comply with the schedule of the largest system in the combined distribution system, which is System A.Bottom line is smaller system sellling water to larger ones need to verify LT2 source testing requirements with state and smaller systems selling water to or buying water from larger systems need to verify their IDSE/Stage 2 schedules with States and /or EPACombined DistributionSystemSubpart H (SW or GWUDI) systems could end up on different schedules for LT2 source monitoring and IDSE/Stage 2 disinfection byproduct monitoring and treatment implementation
5LT2 ESWTR Surface Source Water Microbials Cryptosporidium, E.Coli and Turbidity2 years monthly testing to determine source treatment requirements,Testing cost ~ $25,000-$40,000 per source“grandfather” acceptable data, orAgree to provide full treatmentFirst I will briefly talk about the LT2 Enhanced Surface water treatment rule source water microbial testing –focusing particularly on the Cryptosporidium testing since it is the most challenging and costly—and the results will drive future microbial inactivation and removal requirements.Next slide please
6LT2 Source Monitoring CDS Requirements– 1 year monthly Crypto/E LT2 Source Monitoring CDS Requirements– 1 year monthly Crypto/E.Coli/Turbidity samplingOnly applies to surface water/GUDI systemsPopulation of largest system receiving water determines LT2 source monitoring schedule.If buying water, or considering buying water, from a SW provider, advisable to inquire as to LT2 monitoring and treatment status.Treatment Technique compliance criteria & tracking not yet clearly establishedSystems providing water to large combined systems via current or planned advanced treatment processes may want to go ahead with bin testing rather than agreeing to provide maximum treatment to avoid monitoringCost of PN for future TT violation in case of treatment failure would be substantial
7Stage 2 Disinfection Byproducts Rule Distribution System Monitoring Initial Distribution System Evaluation IDSE Stage 2Trihalomethanes & Haloacetic Acid5 – 1 year testing at multiple new sites every 60 – 90 daysNumber samples based on system populationEntry, Average and Maximum formation sites~$15,000-$85,000 added testing costs for one yearStage 1 testing & compliance continues based on system average through 2011 at least
8Combined Distribution Stage2/IDSE CDS multiple samples per 60 or 90 days for 1 year in addition to Stage 1Wholesale System100,000Consecutive System10,000Consecutive System50,000TreatmentPlantSystem ASystem BSystem CRiverTreatmentPlantRiverThis is an illustration of a combined distribution system.In this example, System A sells water to System B, which in turn sells water to System C. System A is the largest system in the combined distribution system. Therefore, System A complies with the Stage 2 DBPR based on the requirements for a system serving 100,000 people. System B has its own source and sells water to System C. Because System B purchases water from System A, System B must comply with the Stage 2 DBPR schedule based on the population of the largest system in the combined distribution system, which is System A. Even though System C does not sell water and does not have its own source, it is still required to comply with the schedule of the largest system in the combined distribution system, which is System A.Combined DistributionSystemIDSE/Stage 2
9IDSE/Stage 2Wholesale System100,000Wholesale andConsecutive System10,000Consecutive System50,000TreatmentPlantSystem ASystem BSystem CLT2RiverTreatmentPlantRiverLT2This is an illustration of a combined distribution system.In this example, System A sells water to System B, which in turn sells water to System C. System A is the largest system in the combined distribution system. System B has its own source and sells water to System C.For LT2 system A must comply on schedule 1 (>100K). System B serves 10k in its system and sells to system C which serves 50K population therefore, B must comply monitor its source water and implement treatment on Schedule 2 due to selling water to System C with >50K population.For Stage 2 DBPR System A complies based on the requirements for a system serving 100,000 people. But because System B purchases water from System A, System B must comply with the Stage 2 DBPR schedule based on the population of the largest system in the combined distribution system, which is System A. Even though System C does not sell water and does not have its own source, it is still required to comply with the schedule of the largest system in the combined distribution system, which is System A.Bottom line is smaller system sellling water to larger ones need to verify LT2 source testing requirements with state and smaller systems selling water to or buying water from larger systems need to verify their IDSE/Stage 2 schedules with States and /or EPASubpart H (SW or GWUDI) systems could end up on different schedules for LT2 source monitoring and IDSE/Stage 2 disinfection byproduct monitoring and treatment implementation
10IDSE/Stage 2 Distribution Disinfection Byproducts --General RequirementsPurpose of IDSEs:Determine locations of high TTHM and HAA5 concentrations throughout distribution systemResults are used in conjunction with Stage 1 DBPR compliance monitoring to identify and select Stage 2 DBPR compliance monitoring locations (used for LRAA effective 2012 or later)Every PWS must perform separate IDSE and ReportStage 2 sampling may go back to combined system—minimum of 1 sample per systemTo comply with Stage 2 DBPR IDSE Requirements, all CWSs and all NTNCWSs serving at least 10,000 persons that treat their water with a primary or residual disinfectant other than UV or deliver water that has been treated with a primary or residual disinfectant other than UV must qualify for a Very Small System (VSS) Waiver, apply for 40/30 Certification, conduct Standard Monitoring and develop a report, or conduct a System Specific Study and develop a report.
11Stage 2 DBPR 1 2 3 4 Stage 1 continues IDSE Options VSS Waiver 40/30 CertificationStandard MonitoringSystem Specific StudyStage 1 continuesExisting &/or New Data May ApplyThis illustrates the process systems will follow in implementing the Stage 2 DBPR.VSS Waiver: PWS <500 POP, Has DBP data, State has not required IDSENothing else required—no IDSE..proceed to Stage 2 according to deadlines40/30 Certification: 8 consecutive quarters of THM and HAA data at Stage 1 sites with all individual data <40 THM /30HAA. Must submit Certification letter and data by 1st deadline.If approved, no IDSE, proceed to Stage 2 according to deadline.System Specific Study with prior data -- recent (prior) comparable data, 1.5 x SMP sample requirements, certified analysis, representative of system. Must submit SSS report for approval according to deadlines—If approved proceed to Stage 2 according to deadlinesSSS with Hydraulic Model & one round of SMP type data-- Computer model meets IDSE criteria,SMP equivalent samples collected once during peak month & support model predictions. Must submit report for approval. If approved proceed to Stage 2 according to deadlinesChoose Stage 2 TTHM/HAA5 Sites for ComplianceConduct Stage 2 Compliance MonitoringLRAA
12Stage 2 DBPR 1 2 3 4 Stage 1 continues IDSE Options VSS Waiver NOIDSEPrior data1.5 x SMPIDSE OptionsModel0.2 x SMP1234VSSWaiver40/30 CertificationStandard MonitoringSystem Specific StudyStage 1 continuesExisting &/or New Data May ApplyMany will do Standard Monitoring form of IDSE which will involve Disinfection Byproducts (Paired THM and HAA Samples throughout distribution system at specified/approved sites for 1 year – number sites and samples based on population.Lots more samples (about twice the Stage 1 number) on schedules not in sync with ongoing Stage 1 testing60 or 90 day intervals of testing will be required depending on system populationSample schedules and site plans (with schematic) due Oct 1, 2006 for Schedule 1 systems & ConsecutivesStage 1 requirements continue through or later, depending on start scheduleIDSE will be basis for locating highest DBP Stage 2 sites, all of which must meet 80/60 LRAA MCLs in 2012All these options to prepare for Stage 2 require at least some THM and HAA testing within each single public water supply.How systems plan, conduct, document and use this testing will determine much of their success or failure in compliance with Stage 2 disinfection byproducts RuleChoose Stage 2 TTHM/HAA5 Sites for ComplianceConduct Stage 2 Compliance MonitoringLRAA
13TTHM and HAA5 Standard Monitoring(1) For Subpart H systems and systems that purchase Subpart H waterPopulationFrequencyTotalNear EPARTHigh TTHMHigh HAA5<500 consecutive1 (during peak historical month)(2)21-<500 non-consecutive500-3,300 consecutive4 (every 90 days)500-3,300non-consecutive3,301-9,999410,000-49,9996 (every 60 days)8350, ,999165250, ,9992461,000,000-4,999,9993210> 5,000,0004012Standard Monitoring locations and frequencies depend on system size and source water type. This slide shows monitoring frequencies and locations for systems using surface water or GWUDI as a source. Systems must collect TTHM and HAA5 dual sample sets. In a CDS, a system’s Schedule is based on the largest system in its CDS; however, the number of samples a system must collect is based on the individual system’s population, not the largest system in the CDS.EP = entry pointART = average residence timeFootnotes(1) A dual sample set (i.e., a TTHM and an HAA5 sample) must be taken at each monitoring location during each monitoring period.(2) The peak historical month is the month with the highest TTHM or HAA5 levels or warmest water temperature.(1) A dual sample set (i.e., a TTHM and an HAA5 sample) must be taken at each monitoring location during each monitoring period.(2) The peak historical month is the month with the highest TTHM or HAA5 levels or warmest water temperature.
14Challenges for Consecutive Systems Receive water that has already been treatedMay contain DBPsMay contain high levels of precursors and disinfectantsBATs for systems with their own source focus onprecursor removalNot an option for consecutive systemsStage 2 DBPR introduces newBATs for consecutive systemsManagement of distribution system and storageChloraminationConsecutives and wholesalers work together for best alternativesConsecutive systems that are having problems meeting the MCLs for TTHM and HAA5 will face challenges that are different from those faced by non-consecutive systems. The BATs for systems that have their own sources (e.g., GAC, nanofiltration) are based on controlling DBPs through precursor removal. Consecutive systems do not control the treatment trains for the water they purchase. If the water they receive from wholesalers already contains DBPs or precursors and disinfectants that produce DBPs, the Stage 1 DBPR BATs will not address the problem for non-consecutive systems.As a consequence, the Stage 2 DBPR includes:Two BATs for large (> 10,000 people served) consecutive systems: chloramination and management of hydraulic flow and storage to minimize residence time in the distribution system. Chloramination has been used for residual disinfection for many years to minimize the formation of chlorination DBPs, including TTHM and HAA5.One BAT for small (< 10,000 people served) consecutive systems: management of distribution system and storage to minimize water residence time in the distribution system. EPA has not included chloramination as a BAT for small systems because it requires operator supervision and adjustment. Many small systems lack treatment expertise and improper treatment can cause operational difficulties such as nitrification in the distribution system.The BATs for consecutive systems do not focus on precursor removal. EPA still believes that precursor removal remains a highly effective strategy to reduce DBP formation, but recognizes that it is not applicable to consecutive systems. EPA believes that the best compliance strategy for consecutive systems is to collaborate with wholesalers to help achieve the water quality needed.
15Challenges for Consecutive Systems States have taken different approaches in pastMay lack data to determine appropriate monitoring locations for Stage 2 DBPRMay not be eligible for VSS Waiver or 40/30 Certification under IDSE if lacking dataWould need to do Standard Monitoring or SSSWork with wholesalerMay have taken samples in consecutive system’s distribution systemSystem-specific/state-specific regulatory interpretations may applyImportant Speaker’s Note: Tailor this discussion based on whether consecutive systems were required to comply with the Stage 1 DBPR. Consecutive systems might be in decent shape for the Stage 2 DBPR, or they may need a lot of assistance.Because consecutive systems were not specifically addressed under the federal Stage 1 DBPR (although some states required compliance), many consecutive systems do not have data on locations of high TTHM and HAA5 concentrations and may not be able to determine appropriate monitoring locations for their IDSE. They also may not be eligible for some of the IDSE waivers.Consecutive systems are encouraged to contact their wholesale provider as soon as reasonably possible after promulgation of the Stage 2 DBPR to determine what plans, if any, the wholesale system has already made regarding the IDSE.Although each system will have to develop a schedule and plan that is specific to their system, coordinating IDSE monitoring schedules will allow the two (or more) systems to better utilize data from the IDSE monitoring period to formulate a Stage 2 DBPR compliance strategy, if necessary. At a minimum, coordinating the IDSE monitoring schedules helps the wholesale and consecutive system(s) better understand DBP formation across the combined distribution system. Consecutive systems also may want to check with their wholesale system to determine if the wholesaler has conducted monitoring in the consecutive system’s distribution system. If this is the case, the consecutive systems may be able to use this information.
16Tennessee Regulatory Overview & Case Study Examples
17Tennessee Stage 1 Regulations & Case Study Examples Consecutives in combined systems have been included in compliance DBP monitoring and calculations since 1999All systems required to test since except where small systems are surrounded by larger systems (ex. apartment systems)<500 population systems are encouraged to monitor this summer to qualify for VSS waiver.No chloramines allowed in Tennessee to date.Many systems are in compliance using optimized treatment with alternate in-plant pre-filter disinfection (H2O2, enhanced coagulation, P-carbon, G-carbon)Some large systems will qualify for 40/30 certificationTDECTDEC
18Tennessee on the New Regs TDEC Contact:Most TN ground water systems and even some large subpart H systems will qualify for the 40/30 certification. (One TN field office was already issuing 40/30 certifications in April 06.)Systems need to be aware that IDSE System Specific Studies (Modeling or prior DBP data) will be reviewed by the EPA and not the states.Tennessee will expect combined distribution systems to coordinate sampling, so that, for the most part, everyone samples on the same days in order to make the data comparable.Systems encouraged to work closely with the state laboratory certification officers to minimize errors inherent to method used for haloacetic acids. See the August 18, table V-19 Federal Register proposals for details. Surrogate recoveries and other factors need to be looked at in regard to lab results.
19Tennessee on the New Regs TDEC Contact:Systems need to be aware that they should sample early in the compliance period, and insist on analytical results as soon as possible, so that the system can collect additional samples to address abnormally high, or questionable, analytical results before compliance period ends.Systems need to be aware that Stage 2 Rules revise the Stage 1 Rules to require TOC sampling at plants using non-conventional filtration to qualify for reduced monitoring.
20Tennessee on the New Regs TDEC Contact:Because many systems will have to conduct public notice, the health effects issues discussed by the EPA on page 405 and 406 of the January 2006 Federal Register in regard to colon and rectal cancers and negative reproductive outcomes could be included in the public notices to better inform customers of systems with MCL violations.
21Nontraditional water systems Nashville Water DepartmentWest Wilson W.D.Brentwood Water Dept.“Non-Traditional Water Systems”-Property Owners-MHPTotal in CDS: 62This is only an example of why we need systems to work together.Our biggest difficulty at an EPA Region when we conduct the early implementation is providing compliance assistance to what I like to call “nontraditional” water systems. These are water systems whose primary line of business is to sell something or provide a service that has nothing to do with water. That would mean that this group will not be members of AMWA, AWWA or NRWA. The only channel of communication the Agency can rely on is written correspondence, which is easily discarded.The example I’m showing you is in Nashville/Davidson County, Tennessee. This is a common pattern not only in large metropolitan areas, but in the smallest towns where a wholesale source of water is selling to some mobile home parks on the edge of town. It also happens to county water authorities.An EPA Region needs your help, because we lack the local knowledge and the resources to acquire it. The wholesaler is the communications key in the combined distribution system…Source: SDWIS and TN DWS, (compiled by R-IV EPA)
22One County – 89 pubic water supplies Safe Drinking Water Query Form for the State of TennesseeQuery FormSearch the SDWIS Database\Query FormSearch the SDWIS DatabaseOne County – 89 pubic water supplies
244 water providers; 85 purchasers over 500 population –to do IDSE on schedule of largest wholesaler Less than 500 population may qualify for Very Small System Waiverif have TTHM/HAA5 data –— May need to sample this summer….contact TDEC for more information
2534 systems <500 population may qualify for VSS Waiver with DBP results
26Knoxville Utilities Water System Large wholesaling SW System (population 190,324)Low TOC source (Tennessee River)Bin 1 Crypto—with “grandfather-able” dataConventional clarification treatment, chlorine dioxide/free chlorineOne consecutive with multiple wholesalersOther wholesalers have 40/30 CertificationsAll assigned to same Schedule 1 CDS
28Knoxville DBP history -> LT2/Stage 2 IDSE Free chlorinated system—close to 40/30Max month September – DBPs sampled in special studiesUsing fluoride tracers to measure retention time & select SMP IDSE sitesautomatically monitored – fluoride probes configured with data loggerstime for non-fluoride treated water to reach points in system to track water retention timeStudies to extend into consecutive system
29Summary of KUB Fluoride Tracer Studies -- Setup & Results Six probes and data loggersFour separate testing events to-dateNorth, South, East & West system areasSites selected from hydraulic model and general system knowledgeTrack time for fluoride level changesdrop after shutting off fluoride at plantreturn after turning back on at plantVery Interesting findings– an excellent tool.Making distribution operational changes based on test findingsAdditional studies plannedRepeat all tracer tests (as time allows prior to IDSE plan deadline)Longer holding-time SDS for comparison
31Kentucky Regulations & Case Study Examples Consecutives in combined systems have been included in Stage 1 compliance monitoring and compliance tabulations of the combined systems (wholesaler and purchaser) since 1990.Pre-chlorination has been required for most partFew chloraminating systems (larger, some seasonal)State guidance for moving point of chlorination and for conversion to chloramines
32Combined Consecutive Systems have “joint” responsibility for DBP formation and control (under current KY regs)Buyer, purchaser, ConsecutiveSeller, producer, WholesalerTHM/HAA compliance = average of four sites per “joint” (or combined) system
33Consecutive B(<10K): purchased & rechlorinated Wholesaler C (>10K): GW & free chlorine Wholesaler D (<10K): GW & free chlorineConsecutive B(<10K): purchased & rechlorinatedWholesaler A(<10K): SW free chlorine or chloramine seasonal, variableWholesaler F(>50K <100K) SW & chloramines; yearly brief free chlorinationWholesaler G(>100) SW & chloramines) yearly brief free chlorination. Breakpoint free chlorinated as Consec B’s master meter for nitrification control.Wholesaler E (>10K,<50K) SW & chloramines, no yearly free chlorination; water may be purchased from supplier F or G.
34Some systems are already meeting LRAAs (ground water and chloraminating systems) and others have a way to go.Intermittent supply connections<50K>50K>100KChloraminesFree chlorine
35Even large (>300K) system (including multiple consecutives) in compliance using pre-filter Chorine, optimized coagulation and distribution ChloraminesAverage Yearly THM & HAA Levels0.020.040.060.080.10.120.140.16198019841988199219962000THMs/HAAs (mg/l)Ferric ChlorideLowered/RaisedCoagulation pHAlum at high pHFerric PACLPre-Chlorine dioxide Intermediate chlorinationPartnership Turbidity OptimizationChloraminesEVEN LRAAsDistribution Free ChlorineChloramines2004Increased # max sample pointsDecreased # max sample points
36Free Chlorinated System DBPS Wholesaling systems need to be optimized according to Stage 1 requirements and guidance –prior to chloramine conversionState approvals, benchmarking required prior to change impacting treatment CTDistribution retention time must be managedGo to the max site LRAA if you want to know what the future holds1stQ/042ndQ/043rdQ/044th Q/041stQ/052ndQ/05LRAAMax THM541031421068761101Max HAA48685790735266
37Continuous, relatively small volume connections START DATE FOR MONITORING AND COMPLIANCE—DETERMINED BY LARGEST POPULATION SYSTEM IN A COMBINED SYSTEM.States may use knowledge of system to decide whether a smaller system is considered consecutive of the larger for this purpose of IDSE/S2 scheduling.Intermittent supply connections<50K>50K>100K
38How many samples…when?24 Systems: (>100Klargest): IDSE > 54 Stage ISDE site plans due months after promulgationWhere the consecutive system lines are drawn has huge implication for smaller systems’ compliance, labworkloads and sample coordination by multiple utilities.<50K>50K>100K<50K
39For iIlustration purposes only-- All CDS assignments must be verified by KYDOW CDS Schedule 2 (<100K >50K)CDS Schedule 4 (<10K SW &GW)CDS Schedule 34 (<10K SW &GW)<50K>50K>100K<50KCDS : (>100K largest)
40<50K >50K >100K >100K <50K <50K For iIlustration purposes only-- All CDS assignments must be verified by KYDOWCDS Schedule 4 (<10K SW &GW)CDS Schedule 2 (<100K >50K)CDS Schedule 1: (>100K largest)CDS Schedule 3 (<10K SW &GW)<50K>50K>100K>100K<50K<50K<50KCDS Schedule 1: (>100K largest)CDS Schedule 3 (<10K SW &GW)
41IDSE Standard Monitoring Plan – Case Study Louisville Water Company & Consecutives LWC Large Wholesaling (Population 349,000)Surface Water Source (Ohio River, Moderate TOC)Two WTPs conventional treatment plus RBIChlorine,ChloraminesMultiple Consecutive Systems with multiple wholesalers4 separate PWS assigned to LWC CDSConsecs included in Stage 1 DBP complianceContract lab for TTHM & HAA5 testingLWC conducting IDSEs for consecutivesCoordinated w/LWC IDSE/Stage 2 on Schedule 1
44IDSE PlansPlan must be submitted according by October 1 for Schedule 1 systems to include (Use Forms from IDSE Guidance Manuals-filled in examples are included)System ID & descriptionsDescription of processes to select sites, data summaries usedSites IDs with justifications—assess available data & sites in context of known hydraulicsPeak Historical Month BasisSchedule including sampling during max historical monthSchematic – sources, entry points, storage facilities, pressure zones, pumps locations, SMP and Stage 1 Sites (map or schematic scale, minimize use of known landmarks for security)May review larger, complex systems with State prior to submittal
45Finding Maximum DBP Month Highest historical =3rd Quarter (July)May be selected based on historically highest THMs or HAA5s or water temperature
46Finding Maximum DBP Month Highest historical DBP =3rd Quarter (July), Highest temperature = AugMay be selected based on historically highest THMs or HAA5s or water temperatureOther factors may come into play as well… TOC, pH, hydraulics or treatment changes
52Analyzing DBP Formation Factors and projecting Stage 2 compliance Keep track of LRAA at each siteRe-analyze historical data for DBP FP insightsGenerally, chloraminating systems will experience very little DBPs increases with retention time, HAA5s may decrease
53Coordinating IDSE Stage 2 Monitoring and Compliance Efforts in Combined Systems Meetings to train and planEach PWS must conduct separate IDSE and submit plans and reports separatelyStates may allow Combined System DBP sampling for Stage 2 (2012 or later)All individual sites will have to meet LRAA at Stage 2 sitesLarge volume lab economiesTracking and Reporting efficienciesBetter water operations understanding and choices and compliance potential in the long termIDSE/Stage 2 sitesWhere is the oldest water… maps, chlorine residuals.. historic DBP sites & sample results,Representative
54Confounding Issues for all systems Under Stage 2 Maximum LRAA sites may need to move due to system changes.How do we calculate LRAA compliance that is:truly reflective of the water served to a given service area andstill hold systems accountable for minimizing DBPs at a highest max site?IDSE is a snapshot--make best choices to find maximums -- realizing highest LRAA sites/month may/will end up compliance sites/month under Stage 2
55Zone for potential variable supply if chlorine same Free ChlorineGroundwaterVery low TOC & DBPFPHigher hardness, Fe, MnFree ChlorineLimited Surface WaterHigher TOC & DBPFPChloraminesSurface WaterLower TOC & DBPFPNitrificationBooster Chlorine to Free Chlorinate
56? ? New Stage 2 Sample site plan..... IDSE = “ResearchProject” – lots of sites sampled to find Stage 2 sites for future LRAA compliance?New Stage 2 Sample site plan.....based on IDSE..will have to live with itor justify changes.?
57IDSE Sample Site Plans, VSS waiver or 40/30 certification for Schedule 1 Systems Due October 1, 2006!!SEE EPA WEBSITE FOR GUIDANCE MANUALS/FORMS, REGS, TRAINING
58Using Guidance Manual Examples to Understand IDSE Report & Stage 2 Site Selection Follow Guidance manual instructions to review data and select Proposed Stage 2 sitesUse FORM 7 “IDSE Report for Standard Monitoring”
59Sort the data from highest to lowest TTHM LRAA For each site, sum of results for each sample period and divide by number of sample periods for one year = LRAAIf LRAA TTHM results are under mg/L, system is in complianceSort data from highest to lowest HAA5 LRAA—(separate spreadsheet)For each site, sum of results for each sample period and divide by number of sample periods for one year = LRAAIf LRAA HAA5 results are under mg/L, system is in compliance
60Compile all the TTHM data inserting columns to spread the data across the 12 month sampling year. Compile HAA5 data in same format in a separate spreadsheet.
61Sort the data from highest to lowest TTHM LRAA For each site, sum of results for each sample period and divide by number of sample periods for one year = LRAAIf LRAA TTHM results are under mg/L, system is in complianceSort data from highest to lowest HAA5 LRAA—(separate spreadsheet)For each site, sum of results for each sample period and divide by number of sample periods for one year = LRAAIf LRAA HAA5 results are under mg/L, system is in compliance
62Use EPA sequence described in Regulation CFR 141 Use EPA sequence described in Regulation CFR and IDSE Guidance Manual to select Stage 2 sitesReport 3 months after IDSE completed—January for largest systemsStage 2 LRAA compliance will be required after first complete year of testing at new sitesKeep repeating the steps till all Stage 2 sites are selected.
63IPMC Primacy Agencies Regional MDBP Team EPA HQ EI Team HQ SSS Review TeamIPMCPrimacy AgenciesRegional MDBP TeamEPA HQ EI TeamWholesale PWSConsecutive PWSReporting and Tracking Using Multiple People and Methods for Early Implementation
64Effective source selection and use. Optimized DBP precursor removal, chlorine/chloramine applicationsEffective distribution operations, sampling and flushing programs, tank turnover more important than ever.Extended low flow rural/residential areas may need blow offs and/or sampling hydrants to provide sample sites and to ensure routine water turnover.Regular tank turnover and problem area flushing are good– BUT it isnot allowed to just send flushing crews in advance of DBP samplers----IDSE is looking for representative water.
65Take home messages Learn/Know your systems—work together across Plan IDSE sampling in cooperation with State (EPA), wholesale and consecutive systems, working together—look at the big picture and exercise best discretionary options.Apply for VSS Waiver, 40/30 Certification if applicableSubmit IDSE Plans as requiredDon’t overlook the obvious (Find and FIX THE HOT SPOTs--so they don’t end up as max LRAA sites!)Consider future changes--supply, facilities’ configuration, operations– how will they impact DBPs and/or disinfection..or corrosion control??Line up a dependable labs and keep close track of samples and trendsComplete capital changes in time to meet Stage 2 LRAA MCLsIf change is to chloramines; minimize water age, implement a nitrification control plan up front.Remember any disinfection change must be carried out with extreme caution…and State approval.Remember CCR reporting requirements
66Acknowledgements Louisville Water Company & Consecutives Knoxville Utilities BoardKentucky American WaterTennessee Division of Water SupplyKentucky Division of WaterEPA HQ & Region IV EPAFurther Information Contact:Jan Routt & Associates, LLC(859)website: