1. Long Term 2 (LT2) Enhanced Surface Water Treatment Rule
TCEQ
Environmental Trade Fair
May 2015

2. Surface Water Serves majority of people in U.S.
Source for most large systems in Texas
Especially vulnerable to microbial contamination
Cryptosporidium, E. coli, and Giardia lamblia present in most surface water
Series of regulations addresses heightened risk
Surface water includes all water that is open to the atmosphere and subject to surface runoff. This water, which most of the country's large water systems use, includes rivers, lakes, and reservoirs. Surface water is particularly susceptible to microbial contamination from sewage treatment plant discharges and runoff from storm water and snow melt.
Disease-causing microbes such as Crypto, E. coli, and Giardia lamblia are present at varying concentrations in most surface water. The concentration can be much greater after a high rain event due to runoff. Two common sources of microbial contaminants include livestock wastes and septic systems.
EPA has responded to the heightened threat and increased awareness of microbial contamination of surface water sources through a series of rules targeting surface water and GWUDI sources, beginning with the SWTR in The step-approach to regulating surface water sources reflects the progress of EPA’s understanding of surface water contamination.

3. Surface Water Treatment Rules Summary
All Subpart H systems
Reduce risks from Giardia lamblia & viruses
SWTR
(1989)
Subpart H systems serving > 10,000
Address Crypto with improved treatment
IESWTR (1998)
Requirements similar to IESWTR applied to Subpart H systems serving < 10,000
LT1ESWTR (2002)
Target additional treatment at highest-risk systems
LT2ESWTR (2006)
Since the promulgation of the 1989 SWTR, new scientific data has provided a more complete picture of what sources are at the greatest risk for microbial contamination and the effectiveness of treatment for microbial contaminant removal.
The original SWTR focused on reducing the risk of contamination from Giardia lamblia and viruses and applied to all Subpart H systems. The 1998 Interim Enhanced Surface Water Treatment Rule (IESWTR) broadened regulatory focus with the goal of optimizing treatment reliability and to enhance physical removal efficiencies to minimize the Crypto levels in finished water. The Rule also includes disinfection benchmark provisions to ensure continued levels of microbial protection while facilities take the necessary steps to comply with the Stage 1 DBPR standards. The Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR) broadened IESWTR applicability to Subpart H systems of all sizes.
Finally, the LT2ESWTR takes into account new scientific data on Crypto occurrence. The Rule is designed to reduce disease incidence associated with Crypto and other pathogenic microorganisms. The LT2ESWTR will supplement the existing SWTRs by targeting additional Crypto treatment requirements to higher risk systems and mitigating risks from uncovered finished water storage facilities. The Rule will also continue to ensure that systems maintain microbial protection as they take steps to reduce the formation of DBPs.

4. Subpart H Sources
Surface Water – rivers, lakes, reservoirs, canals, etc.
Ground Water Under the Direct Influence of Surface Water (GUI)
Rainwater Collection Systems

5. What is Cryptosporidium?
Protozoan parasite that lives and reproduces in one host
Transmission
Contaminated food or water
Direct contact with feces
Direct or indirect contact with sick individuals
Oocysts are very small: 4-5 microns
Can survive for months without a host

6. Cryptosporidium (Crypto)
Resistant to traditional disinfectants such as free chlorine
Can pass through some filters due to small size
Typical filtration treatment techniques and alternative disinfectants (Chlorine Dioxide, Ozone, UV) can remove and/or inactivate Crypto
Important Speaker’s Note: Point out that we will commonly use “Crypto” as an abbreviation for “Cryptosporidium” for the remaining of the training.
This parasite is present in most surface waters in the U.S. Crypto oocysts have tough walls that are resistant to traditional disinfection practices. While physical removal of Crypto is the most effective method of public health protection, because of their small size, oocysts can sometimes pass through filters.
When ingested, Crypto can cause acute gastrointestinal illness (cryptosporidiosis), which may be severe and is sometimes fatal for people with weakened immune systems. Even low levels of oocysts in finished water can cause illness.
In 1993, a Crypto outbreak in Milwaukee caused intestinal illness in 400,000 people; over 4,000 were hospitalized, and at least 50 deaths have been attributed to the outbreak of cryptosporidiosis. Other recent cryptosporidiosis outbreaks have occurred in Nevada, Oregon, and Georgia.
Much more has been learned about Crypto and treatment methods to avoid contamination since the promulgation of the SWTR.

7. Health Effects of Cryptosporidium
Causes cryptosporidiosis
Mild to sever diarrhea, dehydration, stomach cramps, and slight fever
Immunocompromised individuals can die from infection
No known cure for cryptosporidiosis

8. Cryptosporidiosis Outbreaks in U.S. Municipal Water Supplies
Location
Number of Cases
Year
Carroll County, GA
13,000
1987
Milwaukee, WI
403,000
1993
Clark County, NV
101
Baker County, OR
119
2013
table showing locations of crypto outbreaks, as well as the number of cases and the dates of the outbreaks.

9. Purpose of the LT2ESWTR
Improve public health protection for surface water, GUI, and rainwater systems
Reduce illness caused by Crypto and other microorganisms
Tailor requirements based on:
Level of treatment
Source water quality
Water system size
Provide system with flexibility
In the LT2ESWTR, EPA is addressing a number of public health concerns that remain following implementation of the Interim Enhanced Surface Water Treatment Rule (IESWTR) and Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR), including:
The need for filtered public water systems (PWSs) with higher levels of source water Crypto contamination to provide additional risk-based treatment for Crypto beyond the IESWTR or LT1ESWTR requirements;
The need for unfiltered PWSs to provide risk-based treatment for Crypto to achieve equivalent public health protection with filtered PWSs; and,
The need for PWSs with uncovered finished water storage facilities to take steps to reduce the risk of contamination of treated water prior to distribution to consumers.
The Rule is designed to protect public health by lowering the level of Crypto in finished drinking water to less than 1 oocyst/10,000 L while maintaining public health protection against DBP-related risks (parallel protection is ensured through the simultaneous promulgation of the Stage 2 DBPR).
Current requirements set by the preceding Surface Water Treatment Rules (including 2-log Crypto removal for filtered systems and watershed control programs that minimize the risk of Crypto contamination for unfiltered systems) are adequate for the majority of systems. A subset of PWSs with greater vulnerability to Crypto, however, requires additional treatment. This includes:
Filtered systems with high source water Crypto levels.
Unfiltered systems with high finished water Crypto levels. – none in TX
Systems with uncovered finished water storage facilities. – none in TX
New data also indicate the effectiveness of alternative treatment technologies in reducing finished water Crypto levels, including UV, ozone, and chlorine dioxide.
Other effective practices include watershed management programs, pretreatment processes, and additional clarification and filtration processes. These treatments and practices are incorporated in the LT2ESWTR’s microbial toolbox, which are discussed briefly later in this module and in detail in future trainings.
The LT2ESWTR is flexible because it targets systems with the greatest public health risks and gives them ample choices in how to address these risks.
In addition to improving public health, the data gathered by systems under the initial monitoring phase will help EPA to determine if the SWTRs need to be changed in the future. EPA anticipates that most systems will only need to monitor their source water to comply with the LT2ESWTR.
Finally, the LT2ESWTR is being released concurrently with the Stage 2 DBPR to ensure that the risks from DBPs are adequately balanced against the need for disinfection.

10. LT2ESWTR Overview Source water monitoring
Screening procedure for small systems
Target treatment for highest-risk systems
Additional treatment expected to be the exception instead of the rule

11. LT2ESWTR Process 1 2 3 4 5 Systems Subject to LT2
Initial Round Source Water Monitoring
Bin Classification
Choose Toolbox Option(s)
Implement Tool(s)
Second Round Source Water Monitoring
Systems installing max treatment
Bin 1 systems
Small systems w/ low E. coli 2 1 3 4 5
The LT2ESWTR compliance process involves five steps.
First, systems must conduct initial source water monitoring. Crypto source water monitoring will determine the Crypto risk level for systems. (Though not discussed in depth in this training, Schedule 4 systems may also be conducting E. coli monitoring at this point to determine whether or not Crypto monitoring is necessary, as discussed on the previous slide). Systems can choose to forgo monitoring in favor of installing maximum treatment (i.e., 5.5-log) for Crypto (skipping to Step 3).
Under the second step, systems are classified into “bins,” based on their initial source water monitoring results. Bin classification determines whether the system will be required to provide additional treatment for Crypto and, if so, how much treatment.
Third, systems that are required to increase their current levels of Crypto treatment must choose from a variety of options (organized in a “microbial toolbox”).
Fourth, systems will implement their chosen tool(s).
Note that systems that are classified in Bin 1 are not required to meet the requirements of the third and fourth steps. The requirements associated with each bin will be discussed in more detail in future trainings.
Finally, systems will conduct a second round of source water monitoring in order to determine whether bin reclassification is necessary. This will take place either 6 years after bin classification (filtered systems) or 6 years after the determination of mean Crypto levels (unfiltered systems).

12. Round 2 Start-up Package for Monitoring Plans
Sent out to systems prior to sampling start dates and includes:
Sampling requirements
Sampling location worksheet
Sampling location schematics
Sampling schedules for Crypto and E. coli
TCEQ will send out a package of information for Round 2 sampling under the Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) prior to the start dates set for each schedule. Schedule 1 packages (starting sampling in April 2015) have already been sent out and received. The Schedule 2 (starting sampling in October 2015) will be sent out in May These include a letter from TCEQ explaining the sampling requirements, a sampling location worksheet, sample location schematics, and sampling schedules for Crypto and E. coli.

13. Single Source Sample Location
LT2 Sample point
Backwash water recycle (if applicable)
Water Treatment plant
Source water
Chemical addition
Raw water intake
Raw water chemical building
This slide illustrates the correct location for a sampling point for LT2 purposes. The sample point is before chemical treatment and before the introduction of the filter backwash recycle. This would be permitted for use under the LT2ESWTR however any sample point after treatment or backwash would not be permitted.
This picture illustrates a single source of surface water for a water system. The sample point should be located prior to any chemical addition or backwash water recycling within the water system's facilities. Any sample point after chemical addition and or the backwash recycling will not be permitted for use under the Long Term 2 Enhanced Surface Water Treatment Rule.

14. Multiple Sources Sample Location
Raw water blending station
Raw water intake
Chemical addition
Source water “B”
Source water “A”
LT2 Sample point
Backwash water recycle (if applicable)
Water Treatment plant
This slide illustrates the correct location for multiple sources of surface water for a water system. The sample point should be located prior to any chemical addition or backwash water recycling within the water system's facilities. The sample location should also be indicative of a combination of the two water sources either by collecting at a location after blending or taking a composite sample from each source.
This picture illustrates multiple sources of surface water for a water system. The sample point should be located prior to any chemical addition or backwash water recycling within the water system's facilities. Any sample point after chemical addition and or the backwash recycling will not be permitted for use under the Long Term 2 Enhanced Surface Water Treatment Rule. The sample location should also be indicative of a combination of the two water sources either by collecting at a location after blending or taking a composite sample from each source

15. Schedule and Start Date
Round 2 Schedules
Public Water System Classification
Schedule and Start Date
System serving 100,000 or more people OR a wholesale system in a CDS that contains a system serving >100,000 1
April 1, 2015
System serving 50,000 to 99,999 people OR a wholesale system in a CDS that contains a system serving 50,000 to 99,999 2
October 1, 2015
System serving 10,000 to 49,999 people OR a wholesale system in a CDS that contains a system serving 10,000 to 49,999 3
October 1, 2016
System serving fewer than 10,000 and not a wholesale system 4
October 1, 2017
The schedule categories were established to simplify the discussion of the LT2ESWTR requirements. According to the size, each water system has been designated into specific schedules for sampling. Each schedule has a different start date.
Depending on system size each water system is in a specific schedule for LT2 sampling. Systems serving 100,000 or more people are in Schedule 1 starting sampling on April 1, Schedule 2 systems start sampling on October 1, 2015 and serve between 50,000 to 99,999 people. Any system serving 10,000 to 49,999 people are part of Schedule 3 and will start sampling on October 1, Finally, schedule 4 is made up of systems with fewer than 10,000 people and starts sampling on October 1, 2017.

16. Combined Distribution Systems
The Combined Distribution System (CDS) requirements only apply to systems (wholesalers) that provide (not necessarily sell) water to at least one other PWS
Monitoring requirements are based on the population of the largest water system in a CDS
The “combined distribution system” is the interconnected distribution system consisting of the distribution systems of the wholesale system and of the consecutive systems that receive finished water from that wholesale system. A “wholesale system” is a PWS that treats source water as necessary and then delivers the finished water to another public water system. Delivery may be through a direct connection or through the distribution system of another consecutive system.
Under the LT2ESWTR, wholesale systems in a CDS must comply with the Rule based on the population of the largest system in that combined distribution system. The largest system is not always the wholesale system itself.
Systems that purchase water and do not have their own Subpart H source do not have to comply with all the LT2ESWTR requirements. Source water monitoring requirements will not apply to these systems.

17. Source Water Monitoring Round 2: Schedules 1-3
24 samples plus two matrix spikes required for:
Cryptosporidium
Select an EPA certified lab to conduct Crypto analysis
E. coli
Select a NELAP certified lab to conduct analysis with the approved enumeration method
Turbidity
Conduct turbidity analysis at your own treatment plant

18. Source Water Monitoring Round 2: Schedules 1-3
Matrix spike samples for the 1st and 13th sample
Collect samples within a two-day window on either side of the dates specified in LT2 monitoring plan
Send individual sampling results to the LT2 Program by at by facsimile at , or by correspondence at:
LT2 Program
TCEQ Public Drinking Water Section – MC 155
PO Box 13087
Austin, TX

19. Source Water Monitoring Round 2: Schedule 4
Option to monitor for e. coli instead of Cryptosporidium
Collect one sample every 2 weeks for 12 months (26 samples total)
Cryptosporidium monitoring is triggered if a 12 month running average exceeds 100 colony forming units (CFU) per 100 mL

20. Source Water Monitoring Round 2: Schedule 4
Cryptosporidium Monitoring Options
Once per month for 24 months
Twice per month for 12 months
Samples still must be equally spaced over the 12 or 24 month period

21. Treatment Options Water systems can opt out of source water monitoring
Provide 5.5-log removal/inactivation of Crypto at ALL times
Need to prove the 5.5-log removal/inactivation by a Demonstration of Performance
Also, is source water monitoring is indicating a Bin 4 level of treatment, system can stop monitoring and agree to provide full treatment

22. Treatment Options Consider before choosing treatment:
Currently most systems in Texas are classified as Bin 1 in Texas
There are 9 PWSs (10 plants) classified as Bin 2 systems and required to provide additional treatment at their plants
Full treatment option may be a viable option if you already provide “Bin 1” filtration and use either ozone or UV (see rule CT tables)

23. Calculating Bin Concentration
At the end of testing, TCEQ staff determine the system’s “Bin” level. This will determine the amount of treatment required by the system.
Crypto testing: For 24 to 27 samples, TCEQ calculates the average concentration for every rolling 12 month period and selects the highest average.
E. coli testing: Calculate the average concentration for all samples.

24. Bin Classification
Water systems serving less than 10,000 people which only monitored for E. coli are automatically placed into Bin 1
Does not include small systems which triggered Crypto sampling by having an E. coli average greater than 100 MPN/100mL

25. Levels of Additional Treatment
Average Cryptosporidium Level in the Raw Water
Bin Classification
Minimum Removal/Inactivation Requirement
Cryptosporidium < oocysts/L
Bin 1
2.0-log
0.075 oocysts/L ≤ Cryptosporidium < 1.0 oocysts/L
Bin 2
4.0-log
1.0 oocysts/L ≤ Cryptosporidium < 3.0 oocysts/L
Bin 3
5.0-log
Cryptosporidium ≥ 3.0 oocysts/L
Bin 4
5.5-log
Each system monitoring for source water contamination is divided into a Bin classification. These are dependant on the average level of Cryptosporidium in the raw water. Depending on which Bin classification there is a minimum removal/inactivation requirement. Bin 1 (less than oocysts/ L) systems must have a minimum of 2.0-log. Systems with oocysts/L to less than 1.0 oocysts/L are considered Bin 2 with a requirement of 4.0-log. Bin 3 systems had 1.0 oocysts/L to less than 3.0 oocysts/L must provide a minimum inactivation of 5.0-log. All other systems with 3.0 oocysts/L are Bin 4 systems and required to provide full removal at 5.5-log.

26. Crypto Removal Credits
Treatment plants using coagulation, flocculation, and granular media filtration receive 2,5-log Crypto removal credit.
Treatment plants using coagulation, flocculation, clarification, and granular media filtration receive 3.0-log Crypto removal credit.
TCEQ assigns Crypto removal credit to treatment plants using bag, cartridge, or membrane filters on an individual basis.

27. Microbial Toolbox Options
Watershed control program
Alternative source
Pre-sedimentation basin with coagulation
Two-stage lime softening
Bank filtration
Combined Filter (CFE) Performance
Individual Filter (IFE) Performance
Demonstration of Performance

28. Microbial Toolbox Options
Bag or Cartridge Filters (individual filters)
Bag or Cartridge Filters (in series)
Membrane Filtration
Second stage Filtration
Slow sand Filters
Chlorine dioxide
Ozone
Ultraviolet (UV)

29. Treatment Compliance Deadlines
Population Served
Must comply with Crypto treatment requirements no later than…
100,000 or more
April 1, 2021
50,000 to 99,999
October 1, 2021
10,000 to 49,999
October 1, 2022
Less than 10,000
October 1, 2023
The schedule could be accelerated if the situation is warranted.
All required Cryptosporidium treatment must be implemented by specific dates depending on the size of the water system. With a population served of 100,000 or more treatment must be in place by April 1, October 1, 2021 is the deadline for systems serving 50,000 to 99,999 people. Systems serving 10,000 to 49,999 people will be required to have treatment by October 1, And systems with less than 10,000 people served will have a deadline of October 1, 2023.

30. Treatment Compliance Deadlines
States may allow up to an additional two years for complying with treatment requirements for systems making capital improvements

31. QUESTIONS?
Tamira Konkin-Garcia (512) Sean Ables, P.G. (512)