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Systems Working Together to Comply with New LT2/Stage 2 M/DBPRs KY & TN Wholesale and Consecutive System Case Study Scenarios* Jan C. Routt Jan Routt &

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1 Systems Working Together to Comply with New LT2/Stage 2 M/DBPRs KY & TN Wholesale and Consecutive System Case Study Scenarios* Jan C. Routt Jan Routt & Associates, LLC KY-TN Joint Water Professionals Conference Chattanooga, Tennessee July 10, 2006 *adapted from original presentation, photos omitted for web posting.

2 Implementation Schedule * Treatment Installation Crypto monitoring Treatment Installation Crypto monitoring Treatment Installation Crypto monitoring E. coli Possible Extension Possible Extension IDSE * Includes associated consecutive systems Possible Extension Review submission Review submission Review submission Review submission Compliance LT2 Plan or bin classification due Stage 2 IDSE Plan or report due Possible Extension Treatment Installation Compliance (if no Crypto Monitoring) Compliance (if Crypto Monitoring) Compliance Crypto monitoring WE ARE HERE

3 New Definitions Combined distribution system (CDS) – Interconnected distribution system consisting of the distribution system of wholesale systems and consecutive systems that receive finished water. Combined 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. 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. 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. 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. 40 CFR 141.2

4 Combined Distribution Systems Combined Distribution System Treatment Plant R i v e r Wholesale System100,000 Wholesale and Consecutive System 10,000 Consecutive System50,000 System ASystem BSystem C Treatment Plant River LT2 LT2 Subpart 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

5 LT2 ESWTR Surface Source Water Microbials Cryptosporidium, E.Coli and Turbidity 2 years monthly testing to determine source treatment requirements, 2 years monthly testing to determine source treatment requirements, Testing cost ~ $25,000-$40,000 per source Testing cost ~ $25,000-$40,000 per source grandfather acceptable data, or grandfather acceptable data, or Agree to provide full treatment Agree to provide full treatment

6 LT2 Source Monitoring CDS Requirements– 1 year monthly Crypto/E.Coli/Turbidity sampling Only applies to surface water/GUDI systems Only applies to surface water/GUDI systems Population of largest system receiving water determines LT2 source monitoring schedule. Population 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. 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 established Treatment Technique compliance criteria & tracking not yet clearly established Systems 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 monitoring Systems 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 monitoring Cost of PN for future TT violation in case of treatment failure would be substantial Cost of PN for future TT violation in case of treatment failure would be substantial

7 Stage 2 Disinfection Byproducts Rule Distribution System Monitoring Initial Distribution System Evaluation IDSE Stage 2 Trihalomethanes & Haloacetic Acid5 – 1 year testing at multiple new sites every 60 – 90 days Trihalomethanes & Haloacetic Acid5 – 1 year testing at multiple new sites every 60 – 90 days Number samples based on system population Number samples based on system population Entry, Average and Maximum formation sites Entry, Average and Maximum formation sites ~$15,000-$85,000 added testing costs for one year ~$15,000-$85,000 added testing costs for one year Stage 1 testing & compliance continues based on system average through 2011 at least Stage 1 testing & compliance continues based on system average through 2011 at least

8 Stage2/IDSE CDS multiple samples per 60 or 90 days for 1 year in addition to Stage 1 Combined Distribution System Treatment Plant R i v e r Wholesale System100,000 Consecutive System 10,000 Consecutive System 50,000 System ASystem BSystem C Treatment Plant River IDSE/Stage 2

9 Treatment Plant R i v e r Wholesale System100,000 Wholesale and Consecutive System 10,000 Consecutive System50,000 System ASystem BSystem C Treatment Plant River LT2 LT2 Subpart 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 IDSE/Stage 2

10 IDSE/Stage 2 Distribution Disinfection Byproducts --General Requirements Purpose of IDSEs: Purpose of IDSEs: Determine locations of high TTHM and HAA5 concentrations throughout distribution system Determine locations of high TTHM and HAA5 concentrations throughout distribution system Results 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) Results 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 Report Every PWS must perform separate IDSE and Report Stage 2 sampling may go back to combined systemminimum of 1 sample per system Stage 2 sampling may go back to combined systemminimum of 1 sample per system

11 Stage 2 DBPR VSS Waiver 40/30 Certification Standard Monitoring System Specific Study IDSE Options Choose Stage 2 TTHM/HAA5 Sites for Compliance Conduct Stage 2 Compliance Monitoring LRAA Existing &/or New Data May Apply Stage 1 continues

12 Stage 2 DBPR VSS Waiver 40/30 Certification Standard Monitoring System Specific Study IDSE Options Choose Stage 2 TTHM/HAA5 Sites for Compliance Conduct Stage 2 Compliance Monitoring LRAA Existing &/or New Data May Apply Prior data 1.5 x SMP Model 0.2 x SMP Stage 1 continues NO IDSE

13 TTHM and HAA5 Standard Monitoring (1) For Subpart H systems and systems that purchase Subpart H water For Subpart H systems and systems that purchase Subpart H water PopulationFrequencyTotal Near EP ART High TTHM High HAA5 <500 consecutive 1 (during peak historical month) (2) <500 non-consecutive ,300 consecutive 4 (every 90 days) ,300 non-consecutive ,301-9, ,000-49,999 6 (every 60 days) , , , , ,000,000-4,999, > 5,000, (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.

14 Challenges for Consecutive Systems Receive water that has already been treated Receive water that has already been treated May contain DBPs May contain DBPs May contain high levels of precursors and disinfectants May contain high levels of precursors and disinfectants BATs for systems with their own source focus on BATs for systems with their own source focus on precursor removal Not an option for consecutive systems Not an option for consecutive systems Stage 2 DBPR introduces new Stage 2 DBPR introduces new BATs for consecutive systems Management of distribution system and storage Management of distribution system and storage Chloramination Chloramination Consecutives and wholesalers work together for best alternatives Consecutives and wholesalers work together for best alternatives

15 Challenges for Consecutive Systems States have taken different approaches in past States have taken different approaches in past May lack data to determine appropriate monitoring locations for Stage 2 DBPR May lack data to determine appropriate monitoring locations for Stage 2 DBPR May not be eligible for VSS Waiver or 40/30 Certification under IDSE if lacking data May not be eligible for VSS Waiver or 40/30 Certification under IDSE if lacking data Would need to do Standard Monitoring or SSSWould need to do Standard Monitoring or SSS Work with wholesaler Work with wholesaler May have taken samples in consecutive systems distribution systemMay have taken samples in consecutive systems distribution system System-specific/state-specific regulatory interpretations may applySystem-specific/state-specific regulatory interpretations may apply

16 Tennessee Regulatory Overview & Case Study Examples

17 T ennessee Stage 1 Regulations & Case Study Examples Consecutives in combined systems have been included in compliance DBP monitoring and calculations since 1999 Consecutives in combined systems have been included in compliance DBP monitoring and calculations since 1999 All systems required to test since except where small systems are surrounded by larger systems (ex. apartment systems) All 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. <500 population systems are encouraged to monitor this summer to qualify for VSS waiver. No chloramines allowed in Tennessee to date. No chloramines allowed in Tennessee to date. Many systems are in compliance using optimized treatment with alternate in-plant pre-filter disinfection (H 2 O 2, enhanced coagulation, P-carbon, G-carbon) Many systems are in compliance using optimized treatment with alternate in-plant pre-filter disinfection (H 2 O 2, enhanced coagulation, P-carbon, G-carbon) Some large systems will qualify for 40/30 certification Some large systems will qualify for 40/30 certification TDEC

18 Tennessee on the New Regs 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.) 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. 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. 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, 2003 table V-19 Federal Register proposals for details. Surrogate recoveries and other factors need to be looked at in regard to lab results. 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, 2003 table V-19 Federal Register proposals for details. Surrogate recoveries and other factors need to be looked at in regard to lab results. TDEC Contact:

19 Tennessee on the New Regs 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 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. 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. TDEC Contact:

20 Tennessee on the New Regs 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. 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. TDEC Contact:

21 Nontraditional water systems Nashville Water Department West Wilson W.D. Brentwood Water Dept. Non-Traditional Water Systems -Property Owners -MHP Total in CDS: 62 Source: SDWIS and TN DWS, (compiled by R-IV EPA)

22 One County – 89 pubic water supplies \ Query Form Search the SDWIS Database Query Form Search the SDWIS Database /sdwis/sdwis_query.html Safe Drinking Water Query Form for the State of Tennessee

23 4 water providers; 85 purchasers

24 4 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 Waiver if have TTHM/HAA5 data – May need to sample this summer…. contact TDEC for more information

25 34 systems <500 population may qualify for VSS Waiver with DBP results

26 Knoxville Utilities Water System Large wholesaling SW System (population 190,324) Large wholesaling SW System (population 190,324) Low TOC source (Tennessee River) Low TOC source (Tennessee River) Bin 1 Cryptowith grandfather-able data Bin 1 Cryptowith grandfather-able data Conventional clarification treatment, chlorine dioxide/free chlorine Conventional clarification treatment, chlorine dioxide/free chlorine One consecutive with multiple wholesalers One consecutive with multiple wholesalers Other wholesalers have 40/30 CertificationsOther wholesalers have 40/30 Certifications All assigned to same Schedule 1 CDS All assigned to same Schedule 1 CDS

27 KUB W1 CS1 (SG) W2 (NM) W3 (JC) W3 (SV) W4 (NP) CS2 (DD)

28 Knoxville DBP history -> LT2/Stage 2 IDSE Free chlorinated systemclose to 40/30 Free chlorinated systemclose to 40/30 Max month September – DBPs sampled in special studies Max month September – DBPs sampled in special studies Using fluoride tracers to measure retention time & select SMP IDSE sites Using fluoride tracers to measure retention time & select SMP IDSE sites automatically monitored – fluoride probes configured with data loggers automatically monitored – fluoride probes configured with data loggers time for non-fluoride treated water to reach points in system to track water retention time time for non-fluoride treated water to reach points in system to track water retention time Studies to extend into consecutive system Studies to extend into consecutive system

29 Summary of KUB Fluoride Tracer Studies -- Setup & Results Six probes and data loggers Six probes and data loggers Four separate testing events to-date Four separate testing events to-date North, South, East & West system areas North, South, East & West system areas Sites selected from hydraulic model and general system knowledge Sites selected from hydraulic model and general system knowledge Track time for fluoride level changes Track time for fluoride level changes drop after shutting off fluoride at plant drop after shutting off fluoride at plant return after turning back on at plant return after turning back on at plant Very Interesting findings– an excellent tool. Very Interesting findings– an excellent tool. Making distribution operational changes based on test findings Making distribution operational changes based on test findings Additional studies planned Additional studies planned Repeat all tracer tests (as time allows prior to IDSE plan deadline) Repeat all tracer tests (as time allows prior to IDSE plan deadline) Longer holding-time SDS for comparison Longer holding-time SDS for comparison

30 Kentucky Regulations & Case Study Examples

31 Consecutives in combined systems have been included in Stage 1 compliance monitoring and compliance tabulations of the combined systems (wholesaler and purchaser) since Consecutives in combined systems have been included in Stage 1 compliance monitoring and compliance tabulations of the combined systems (wholesaler and purchaser) since Pre-chlorination has been required for most part Pre-chlorination has been required for most part Few chloraminating systems (larger, some seasonal) Few chloraminating systems (larger, some seasonal) State guidance for moving point of chlorination and for conversion to chloramines State guidance for moving point of chlorination and for conversion to chloramines

32 THM/HAA compliance = average of four sites per joint (or combined) system Combined Consecutive Systems have joint responsibility for DBP formation and control (under current KY regs) Buyer, purchaser, Consecutive Seller, producer, Wholesaler

33 Wholesaler A(<10K): SW free chlorine or chloramine seasonal, variable Consecutive B(<10K): purchased & rechlorinated Wholesaler C (>10K): GW & free chlorine Wholesaler D ( 10K): GW & free chlorine Wholesaler D (<10K): GW & free chlorine Wholesaler E (>10K, 10K,<50K) SW & chloramines, no yearly free chlorination; water may be purchased from supplier F or G. Wholesaler G(>100) SW & chloramines) yearly brief free chlorination. Breakpoint free chlorinated as Consec Bs master meter for nitrification control. Wholesaler F(>50K 50K <100K) SW & chloramines; yearly brief free chlorination

34 Some systems are already meeting LRAAs (ground water and chloraminating systems) and others have a way to go. >50K <50K >100K Intermittent supply connections Chloramines Free chlorine

35 Average Yearly THM & HAA Levels THMs/HAAs (mg/l) Ferric Chloride Lowered/Raised Coagulation pH Alum at high pH Ferric PACL Pre-Chlorine dioxide Intermediate chlorination Chloramines Partnership Turbidity Optimization Distribution Free Chlorine Increased # max sample points Decreased # max sample points 2004 Even large (>300K) system (including multiple consecutives) in compliance using pre-filter Chorine, optimized coagulation and distribution Chloramines EVEN LRAAs Chloramines

36 Free Chlorinated System DBPS 1stQ/0 42ndQ/043rdQ/04 4th Q/041stQ/05 2ndQ/0 5 LRA A Max THM Max HAA Wholesaling systems need to be optimized according to Stage 1 requirements and guidance –prior to chloramine conversion State approvals, benchmarking required prior to change impacting treatment CT Distribution retention time must be managed Go to the max site LRAA if you want to know what the future holds

37 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. >50K <50K >100K Intermittent supply connections Continuous, relatively small volume connections

38 Where the consecutive system lines are drawn has huge implication for smaller systems compliance, lab workloads and sample coordination by multiple utilities. <50K >100K <50K >50K How many samples…when? 24 Systems: (>100Klargest): IDSE > 54 Stage 2 ISDE site plans due 6 months after promulgation

39 <50K >100K <50K >50K CDS Schedule 4 (<10K SW &GW) CDS Schedule 2 ( 50K) CDS : (>100K largest) CDS Schedule 34 (<10K SW &GW) For iIlustration purposes only-- All CDS assignments must be verified by KYDOW

40 <50K >100K <50K >50K CDS Schedule 4 (<10K SW &GW) CDS Schedule 2 ( 50K) CDS Schedule 1: (>100K largest) CDS Schedule 3 (<10K SW &GW) CDS Schedule 1: (>100K largest) >100K < 50K CDS Schedule 3 (<10K SW &GW) For iIlustration purposes only-- All CDS assignments must be verified by KYDOW

41 IDSE Standard Monitoring Plan – Case Study Louisville Water Company & Consecutives LWC Large Wholesaling (Population 349,000) LWC Large Wholesaling (Population 349,000) Surface Water Source (Ohio River, Moderate TOC) Surface Water Source (Ohio River, Moderate TOC) Two WTPs conventional treatment plus RBI Two WTPs conventional treatment plus RBI Chlorine,Chloramines Chlorine,Chloramines Multiple Consecutive Systems with multiple wholesalers Multiple Consecutive Systems with multiple wholesalers 4 separate PWS assigned to LWC CDS 4 separate PWS assigned to LWC CDS Consecs included in Stage 1 DBP compliance Consecs included in Stage 1 DBP compliance Contract lab for TTHM & HAA5 testing Contract lab for TTHM & HAA5 testing LWC conducting IDSEs for consecutives LWC conducting IDSEs for consecutives Coordinated w/LWC IDSE/Stage 2 on Schedule 1 Coordinated w/LWC IDSE/Stage 2 on Schedule 1

42 LWC W1 CS1 CS3 CS5 CS4 W2 W3 CS2 W4 W5 W6

43 LWC W1 CS1 CS3 CS4 W2 W3 CS2

44 IDSE Plans Plan must be submitted according by October 1 for Schedule 1 systems to include (Use Forms from IDSE Guidance Manuals-filled in examples are included) Plan 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 & descriptions System ID & descriptions Description of processes to select sites, data summaries used Description of processes to select sites, data summaries used Sites IDs with justificationsassess available data & sites in context of known hydraulics Sites IDs with justificationsassess available data & sites in context of known hydraulics Peak Historical Month Basis Peak Historical Month Basis Schedule including sampling during max historical month Schedule including sampling during max historical month Schematic – 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) Schematic – 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 May review larger, complex systems with State prior to submittal

45 Finding Maximum DBP Month May be selected based on historically highest THMs or HAA5s or water temperature May be selected based on historically highest THMs or HAA5s or water temperature Highest historical = 3 rd Quarter (July)

46 Finding Maximum DBP Month May be selected based on historically highest THMs or HAA5s or water temperature May be selected based on historically highest THMs or HAA5s or water temperature Other factors may come into play as well… TOC, pH, hydraulics or treatment changes Other factors may come into play as well… TOC, pH, hydraulics or treatment changes Highest historical DBP = 3 rd Quarter (July), Highest temperature = Aug

47 Stage 1 & IDSE Scheduling PopOctNovDecJanFebMarAprMayJunJulAugSepTotal LWC Wholesaler836,925 Stage IDSE SM Consec 14,290 Stage IDSE SM Consec 215,717 Stage IDSE SM Consec 3 12,823 Stage IDSE SM Consec 4 12,500 Stage IDSE SM Total

48 Stage 1 & IDSE Scheduling PopOctNovDecJanFebMarAprMayJunJulAugSepTotal LWC Wholesaler836,925 Stage IDSE SM Consec 14,290 Stage IDSE SM Consec 215,717 Stage IDSE SM Consec 3 12,823 Stage IDSE SM Consec 4 12,500 Stage IDSE SM Total

49 Stage 1 & IDSE Scheduling PopOctNovDecJanFebMarAprMayJunJulAugSepTotal LWC Wholesaler836,925 Stage IDSE SM Consec 14,290 Stage IDSE SM Consec 215,717 Stage IDSE SM Consec 3 12,823 Stage IDSE SM Consec 4 12,500 Stage IDSE SM Total

50 Stage 1 & IDSE Scheduling PopOctNovDecJanFebMarAprMayJunJulAugSepTotal LWC Wholesaler836,925 Stage IDSE SM Consec 14,290 Stage IDSE SM Consec 215,717 Stage IDSE SM Consec 3 12,823 Stage IDSE SM Consec 4 12,500 Stage IDSE SM Total

51 Stage 1 & IDSE Scheduling PopOctNovDecJanFebMarAprMayJunJulAugSepTotal LWC Wholesaler836,925 Stage IDSE SM Consec 14,290 Stage IDSE SM Consec 215,717 Stage IDSE SM Consec 3 12,823 Stage IDSE SM Consec 4 12,500 Stage IDSE SM Total

52 Analyzing DBP Formation Factors and projecting Stage 2 compliance Keep track of LRAA at each site Keep track of LRAA at each site Re-analyze historical data for DBP FP insights Re-analyze historical data for DBP FP insights Generally, chloraminating systems will experience very little DBPs increases with retention time, HAA5s may decrease Generally, chloraminating systems will experience very little DBPs increases with retention time, HAA5s may decrease

53 Coordinating IDSE Stage 2 Monitoring and Compliance Efforts in Combined Systems Meetings to train and plan Meetings to train and plan Each PWS must conduct separate IDSE and submit plans and reports separately Each PWS must conduct separate IDSE and submit plans and reports separately States may allow Combined System DBP sampling for Stage 2 (2012 or later) States may allow Combined System DBP sampling for Stage 2 (2012 or later) All individual sites will have to meet LRAA at Stage 2 sites All individual sites will have to meet LRAA at Stage 2 sites Large volume lab economies Large volume lab economies Tracking and Reporting efficiencies Tracking and Reporting efficiencies Better water operations understanding and choices and compliance potential in the long term Better water operations understanding and choices and compliance potential in the long term IDSE/Stage 2 sites Where is the oldest water… maps, chlorine residuals.. historic DBP sites & sample results, Representative

54 Confounding Issues for all systems Under Stage 2 Maximum LRAA sites may need to move due to system changes. Under Stage 2 Maximum LRAA sites may need to move due to system changes. How do we calculate LRAA compliance that is: How do we calculate LRAA compliance that is: truly reflective of the water served to a given service area and truly reflective of the water served to a given service area and still hold systems accountable for minimizing DBPs at a highest max site? still 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 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

55 Zone for potential variable supply if chlorine same Chloramines Surface Water Lower TOC & DBPFP Nitrification Booster Chlorine to Free Chlorinate Free Chlorine Groundwater Very low TOC & DBPFP Higher hardness, Fe, Mn Free Chlorine Limited Surface Water Higher TOC & DBPFP

56 ? ? IDSE = Research Project – lots of sites sampled to find Stage 2 sites for future LRAA compliance

57 IDSE 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

58 Using Guidance Manual Examples to Understand IDSE Report & Stage 2 Site Selection Follow Guidance manual instructions to review data and select Proposed Stage 2 sites Follow Guidance manual instructions to review data and select Proposed Stage 2 sites Use FORM 7 IDSE Report for Standard Monitoring Use FORM 7 IDSE Report for Standard Monitoring

59 Sort 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 = LRAA If LRAA TTHM results are under mg/L, system is in compliance Sort 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 = LRAA If LRAA HAA5 results are under mg/L, system is in compliance

60 Compile 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.

61 Sort 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 = LRAA If LRAA TTHM results are under mg/L, system is in compliance Sort 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 = LRAA If LRAA HAA5 results are under mg/L, system is in compliance

62 Use EPA sequence described in Regulation CFR and IDSE Guidance Manual to select Stage 2 sites Report 3 months after IDSE completed January for largest systems Stage 2 LRAA compliance will be required after first complete year of testing at new sites Keep repeating the steps till all Stage 2 sites are selected.

63 Regional MDBP Team IPMC EPA HQ EI Team Primacy Agencies HQ SSS Review Team Consecutive PWS Wholesale PWS Reporting and Tracking Using Multiple People and Methods for Early Implementation

64 Effective source selection and use. Effective source selection and use. Optimized DBP precursor removal, chlorine/chloramine applications Optimized DBP precursor removal, chlorine/chloramine applications Effective distribution operations, sampling and flushing programs, tank turnover more important than ever. Effective 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. 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 is not allowed to just send flushing crews in advance of DBP samplers--- -IDSE is looking for representative water.

65 Take home messages Learn/Know your systemswork together across Learn/Know your systemswork together across Plan IDSE sampling in cooperation with State (EPA), wholesale and consecutive systems, working togetherlook at the big picture and exercise best discretionary options. Plan IDSE sampling in cooperation with State (EPA), wholesale and consecutive systems, working togetherlook at the big picture and exercise best discretionary options. Apply for VSS Waiver, 40/30 Certification if applicable Apply for VSS Waiver, 40/30 Certification if applicable Submit IDSE Plans as required Submit IDSE Plans as required Dont overlook the obvious (Find and FIX THE HOT SPOTs--so they dont end up as max LRAA sites!) Dont overlook the obvious (Find and FIX THE HOT SPOTs--so they dont end up as max LRAA sites!) Consider future changes--supply, facilities configuration, operations– how will they impact DBPs and/or disinfection..or corrosion control?? 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 trends Line up a dependable labs and keep close track of samples and trends Complete capital changes in time to meet Stage 2 LRAA MCLs Complete capital changes in time to meet Stage 2 LRAA MCLs If change is to chloramines; minimize water age, implement a nitrification control plan up front. If 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 any disinfection change must be carried out with extreme caution…and State approval. Remember CCR reporting requirements Remember CCR reporting requirements

66 Acknowledgements Louisville Water Company & Consecutives Louisville Water Company & Consecutives Knoxville Utilities Board Knoxville Utilities Board Kentucky American Water Kentucky American Water Tennessee Division of Water Supply Tennessee Division of Water Supply Kentucky Division of Water Kentucky Division of Water EPA HQ & Region IV EPA EPA HQ & Region IV EPA Further Information Contact: Jan Routt & Associates, LLC (859) website: website:


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