1. Stage 1 and 2 Disinfection Byproduct Rule presented by: Joseph Munson

2. Outline Introduction to Disinfection ByproductsIntroduction to Disinfection Byproducts Stage 1 & 2 OverviewStage 1 & 2 Overview Initial Distribution System Evaluation (IDSE) OptionsInitial Distribution System Evaluation (IDSE) Options Stage 2 ComplianceStage 2 Compliance DCTSDCTS IDSE ToolIDSE Tool

3. Disinfectants: Kill or inactivate disease-causing microorganismsKill or inactivate disease-causing microorganisms React with substances naturally in water to form harmful DBPsReact with substances naturally in water to form harmful DBPs Produce negative health effects when present in excessive levelsProduce negative health effects when present in excessive levels Public Health & Disinfection

4. How Are DBPs Formed? Precursor in Water NOM Bromide + Added Disinfectant Chlorine Chloramines Chlorine Dioxide Ozone = TTHM HAA5 Chlorite Bromate DBP

5. Health Effects DisinfectantsDisinfectants (in large doses): −Eye and nose irritation −Stomach discomfort −Anemia −Other acute short- term health effects Byproducts:Byproducts: −Cancer −Liver problems −Kidney problems −Central nervous system problems −Anemia −Reproductive problems

6. A Delicate Balance Risk: microbial contamination vs. DBP formation Risk: microbial contamination vs. DBP formation EPA’s solution: control health risks from microbials, disinfectants, and DBPs EPA’s solution: control health risks from microbials, disinfectants, and DBPs Result: M-DBP Suite of rules Result: M-DBP Suite of rules Microbials DBP’s

7. Stage 1 & 2 DBPR Overview

8. Stage 1 − − Applied to all community and nontransient noncommunity water systems that add a chemical disinfectant. − − 221 systems in South Dakota are complying with Stage 1 regulations. Stage 2 − − Will apply to all community and nontransient noncommunity water systems that add a chemical disinfectant or that purchase water with an added chemical disinfectant. − − 403 systems in South Dakota will have to comply with Stage 2 regulations. The requirements that apply to each system depend on treatment process and type of source water.

9. Population-Based Monitoring and Scheduling Stage 1 DBPRStage 1 DBPR –Scheduling based on source water type and population served –Monitoring based on source water type, population served, and number of treatment plants/wells Stage 2 DBPRStage 2 DBPR –Scheduling based on source water type, population served, and population of the largest system in combined distribution system (CDS) –Monitoring based on source water type and population served (excluding CDS)

10. Combined Distribution Systems (CDSs) All systems in a CDS (i.e., wholesalers, consecutive systems) must comply with Stage 2 DBPR requirements on the same scheduleAll systems in a CDS (i.e., wholesalers, consecutive systems) must comply with Stage 2 DBPR requirements on the same schedule –Compliance date is based on the population of the largest system in the CDS –Compliance date is based on the population of the largest system in the CDS –Largest system is not necessarily the wholesaler EPA or state has discretion to determine CDSEPA or state has discretion to determine CDS –Emergency or seasonal connections

11. Consecutive Systems Must comply with IDSE requirementsMust comply with IDSE requirements Must conduct Stage 2 DBPR TTHM and HAA5 compliance monitoringMust conduct Stage 2 DBPR TTHM and HAA5 compliance monitoring Must comply with the Stage 1 DBPR requirements for chlorine and chloraminesMust comply with the Stage 1 DBPR requirements for chlorine and chloramines

12. Compliance Calculation & Reporting Stage 1 − − Calculate compliance at the end of every quarter in which the system monitors using the Running Annual Average (RAA) of results from the last 12 months and compare to MCL Stage2 − −Calculate compliance at the end of every quarter in which the system monitors using a Locational Running Annual Average (LRAA).   Systems must report a LRAA for every site they sample at and each LRAA must be below the MCL. Compliance Reporting for Stage 1 & 2 − − Within 10 days of the end of each quarter in which samples are taken, report RAA or LRAA, MCL violations, and information about samples to the state. − − Consecutive systems must begin complying with the Stage 1 DBPR requirements for chlorine and chloramines beginning April 1, 2009. Each system must submit a quarterly chlorine residual to the state within 10 days of the end if each quarter.

13. MRDLs Stage 1 & 2 DBPR MRDL & MCL DisinfectantMRDL Chlorine 4.0 mg/L Chloramines Chlorine Dioxide 0.8 mg/L Disinfection Byproduct MCLTTHM 0.080 mg/L HAA5 0.060 mg/L Bromate 0.010 mg/L Chlorite 1.0 mg/L MCLs

14. Initial Distribution System Evaluation (IDSE) Options

15. 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 1342 Existing Data OnlyNew and Existing Data

16. Sch. Systems Serving: Submit 40/30 Certification, SM, SSS Plan, or receive VSS Waiver by: Complete SM or SSS By: Submit IDSE Report (only systems conducting SM or SSS) by: 1 > 100,000 > 100,000 Oct. 1, 2006 Sept. 30, 2008 Jan. 1, 2009 2 50,000–99,999 50,000–99,999 Apr. 1, 2007 Mar. 31, 2009 July 1, 2009 3 10,000–49,999 10,000–49,999 Oct. 1, 2007 Sept. 30, 2009 Jan. 1, 2010 4 < 10,000 < 10,000 Apr. 1, 2008 Mar. 31, 2010 July 1, 2010 Schedule for systems in a combined distribution system is based on that of the largest system in the combined distribution system IDSE Implementation Timeline

17. Very Small System (VSS) Waivers IDSE Options

18. Eligibility Criteria Systems mustSystems must –Serve fewer than 500 people –Have taken TTHM and HAA5 samples  Reduced monitoring acceptable  Operational data acceptable 137 systems out of an eligible 243 systems in South Dakota have received their VSS Waiver137 systems out of an eligible 243 systems in South Dakota have received their VSS Waiver Note: EPA or the state may deny a VSS Waiver for any reason, even if system meets all eligibility criteria

19. VSS Waivers Waivers effective immediatelyWaivers effective immediately − No application necessary − Systems must meet all criteria EPA or the state can require Standard Monitoring or System Specific StudyEPA or the state can require Standard Monitoring or System Specific Study VSS Waiver is only a waiver from additional IDSE activitiesVSS Waiver is only a waiver from additional IDSE activities − No Standard Monitoring or System Specific Study Plan − No IDSE Report Continue compliance with Stage 1 DBPR until Stage 2 DBPR compliance beginsContinue compliance with Stage 1 DBPR until Stage 2 DBPR compliance begins –Complete a monitoring plan for the Stage 2 DBPR

20. 40/30 Certification

21. Eligibility Criteria Systems must have Stage 1 DBPR data equivalent to 8 quarters worth of data: − −No individual sample can have exceeded:   0.040 mg/L for TTHM   0.030 mg/L for HAA5 − −No TTHM or HAA5 monitoring violations − −For schedule 3 and 4 systems data can not be before January 1, 2005 Approximately 88 systems in South Dakota will be eligible for a 40/30 Certification Note: EPA or the state may deny the certification for any reason, even if system meets all eligibility criteria

22. Operational Data EPA or the state may allow systems to use operational data to qualify for certificationEPA or the state may allow systems to use operational data to qualify for certification –Should be equivalent to Stage 1 DBPR data ConsiderationsConsiderations –Samples taken and analyzed by approved methods at a certified lab –Adequate number of sample sites for system size –Samples taken at appropriate locations (average to maximum residence time) –Samples taken at appropriate frequency and during month of warmest water temperature

23. Submitting a 40/30 Letter Once a system has collected a sufficient amount of data it can prepare a 40/30 Certification Letter and submit it to the EPA:Once a system has collected a sufficient amount of data it can prepare a 40/30 Certification Letter and submit it to the EPA: –Electronically (through IDSE tool) –Hard-copy (through mail)  US EPA-IPMC PO Box 98 Dayton, OH 45401-0098

24. System Information PWS Name_____________________ PWS ID:_______________________ Street Address:__________________ City, State, Zip:_________________ Population Served:_______________ Source Water Type:  Ground  Subpart H System Type:  CWS  NTNCWS Combined Distribution System:  Wholesale  Consecutive  Neither Contact Person Name:_______________________Title: ____________________ Phone Number:__________________Fax Number (if available):____________ Email Address (if available):_______________________ Certification I hereby certify that each individual Stage 1 DBPR compliance sample collected from ________ to _______ was less than or equal to 0.040 mg/L for TTHM and 0.030 mg/L for HAA5. I understand that to be eligible, each individual sample must be equal to or below these values. I also certify that this PWS collected all required Stage 1 samples and did not have any monitoring violations during this time period. Signature:_________________ Date:______________________ Example 40/30 Certification Letter

25. Standard Monitoring

26. Standard Monitoring IDSE Steps Select Standard Monitoring Locations Prepare and Submit Standard Monitoring Plan Conduct Standard Monitoring Select Stage 2 DBPR compliance monitoring locations Prepare and Submit IDSE report 1 2 3 4 5 EPA or the state approves the Standard Monitoring Plan

27. IDSE Schedule for Standard Monitoring Sch. Systems Serving Submit Plan Complete Monitoring Submit IDSE Report 1 > 100,000 10/1/20069/30/20081/1/2009 2 50,000 – 99,999 4/1/20073/31/20097/1/2009 3 10,000 – 49,999 10/1/20079/30/20091/1/2010 4 < 10,000 4/1/20083/31/20107/1/2010 Schedule for systems in a combined distribution system is based on that of largest system in the combined distribution system

28. Required Components of Standard Monitoring Plan Distribution system schematic – –Entry points, sources, and storage facilities – –Locations and dates of proposed Standard Monitoring sites – –Locations and dates of Stage 1 DBPR monitoring sites Population served Source water type Justification of Standard Monitoring sites – –Must include a summary of data used to justify selection of Standard Monitoring sites

29. Standard Monitoring Requirements What, where, and how often do I monitor? – –Samples Collected   Dual sample set (both TTHM and HAA5) collected at all locations – –Monitoring Locations   High TTHM levels   High HAA5 levels   Average Residence Time   Near Entry Points – –Number of sites   Based on system’s source water type and population served – –Monitoring Frequency   1, 4, or 6 monitoring periods during the year at each location   Number based on population served and source type

30. TTHM and HAA5 Standard Monitoring (1) For groundwater systems or systems that purchase groundwaterFor groundwater systems or systems that purchase groundwater Population Frequency (in year) Total Sites Near EP ART High TTHM High HAA5 < 500 consecutive 1 (during peak historical month) (2) 21-1- < 500 non- consecutive 2--11 500-9,999 4 (every 90 days) 2--11 10,000 – 99,999 61122 100,000-499,99981133 (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.

31. TTHM and HAA5 Standard Monitoring (1) For Subpart H systems and systems that purchase Subpart H waterFor 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) 21-1- <500 non-consecutive 2--11 500-3,300 consecutive 4 (every 90 days) 21-1- 500-3,300non-consecutive2--11 3,301-9,9994-121 10,000-49,999 6 (every 60 days) 81232 50,000- 249,999 163454

32. Standard Monitoring Site Selection – Justification Plan must include a justification for the selection of sites to be sampled during Standard MonitoringPlan must include a justification for the selection of sites to be sampled during Standard Monitoring Data sources and toolsData sources and tools –Distribution system maps –Water quality data –Distribution system operating data

33. Final “Selected” Sites Some site selection will be obviousSome site selection will be obvious –Near entry point Others will require professional judgmentOthers will require professional judgment –Consider geographic representation –Consider hydraulic representation –Consider areas fed by sources with higher DBP precursors –Use sites that “multi-task” –Consider accessibility

34. Submitting Standard Monitoring Plan Once the system has collected and analyzed its information, it must prepare the plan and submit it to EPA or the stateOnce the system has collected and analyzed its information, it must prepare the plan and submit it to EPA or the state –Electronically (through IDSE tool) –Hard-copy (mail to IPMC address) Must include required informationMust include required information

35. System Specific Study (SSS)

36. Stage 2 Compliance Monitoring Schedule Sch.SystemServing: Start Stage 2 Compliance Monitoring By: 1 > 100,000 April 1, 2010 2 50,000 –99,999 Oct. 1, 2012 3 10,000 –49,999 Oct. 1, 2013 4 < 10,000 Oct 1, 2013 Oct 1, 2014* Oct 1, 2014* * Date for systems that were required to conduct Crypto monitoring under LT2

37. Questions?

38. Information Processing & Management Center (IPMC) and Data Collection & Tracking System (DCTS)

39. Information Processing and Management Center (IPMC) What is the IPMC? − − It’s a centralized location to process hard copy Stage 2 DBPR & LT2ESWTR submissions What is the Goal of the IPMC? − − To conduct administrative tasks such as data entry and mail distribution for the Regions and states − − Have one mailing address that would process all the Stage 2 DBPR & LT2ESWTR submissions

40. What can be submitted to the IPMC? For Stage 2 DBPR: – –40/30 Certifications – –Standard Monitoring Plans – –System Specific Study Plans   Extensive Data   Hydraulic Modeling IDSE Reports

41. IPMC Contact Information The IPMC will receive, sort, scan, & perform data entry for Stage 2 DBPR and LT2ESWTR submissions into the DCTS. Mailing Address: Stage 2 DBPR & LT2ESWTR IPMC P O Box 98 Dayton, OH 45401 Fax Number: 937-586-6557 E-mail Address: stage2mdbp@epa.gov

42. Data Collection & Tracking System (DCTS) What is the DCTS? – –It’s a database that will track and store Stage 2 DBPR and LT2ESWTR early implementation submissions – –For Stage 2 DBPR, gives you access to the online IDSE tool   Develop and submit your 40/30 Certification or IDSE Plan or Report online

43. Accessing the IDSE Tool There are many ways to access the IDSE Tool – –Online   CDX username and password required   Submit information electronically to EPA – –CD Version   Download or request from EPA warehouse   E-mail, fax, or mail information to EPA – –Hard Copy Template   From IDSE Guidance Manual   Fill in template by hand   Mail information to EPA

44. Accessing the IDSE Tool Both the online and the CD version of the IDSE Tool have access to the Wizard and the Plan/Report Entry feature – –Wizard determines which IDSE option is best for the system – –IDSE Plan/Report Entry feature creates custom forms for the selected IDSE option and helps the system complete electronic forms

45. Accessing DCTS There are two ways to register for DCTS: – –Using a CRK key   EPA began distributing CRK keys to PWSs in Summer 2006 (according to system schedule) – –Via the CDX Web site

46. Access Request Process for Individuals With a CRK Key What is a CRK Key? – –User name and password that allows first time users to login to the DCTS if the user does not already have access through other applications Who will receive a CRK Key? – –Administrative users (the first user associated with an organization) will receive the CRK Key in the mail – –Do not change provided user name to ensure pre-registration works!

47. User Approval within DCTS Administrative users in each organization will be responsible for approving all standard users – –Admin user must be registered before others can use the DCTS for their organization – –Some admin users may be linked to more than one organization (e.g., DCTS users with multiple PWSs)   Commonly used by those who work for a PWS organization

48. CRK Access Go to: http://cdx.epa.gov/preregistrationhttp://cdx.epa.gov/preregistration

49. What if I Did Not Receive a CRK Letter and Need to Register?

50. Access Request Process We recommend that you use the Registration Guide (sent with email handout) Go to https://cdx.epa.govhttps://cdx.epa.gov

51. Access Request Process Access Request Process Steps for New DCTS Users with No CRK and No Previous Interaction with CDX: Step A – –Apply for access via EPA’s CDX Web site Step B – –Read and sign the warning notice, privacy statement, and terms and conditions – –Fill out User and Organization information Step C – –Select: “LT2ESWTR: LT2ESWTR, Stage 2 DBPR, and IDSE Plan/Report Entry” from the list of CDX applications

52. Add Program: Add Program: Step C for All Users

53. Access Request Process Access Request Process Steps for New DCTS Users with No CRK: Step D: Select – –Role Dropdown Menu: “A Submitter” – –Program ID Type: “Standard” – –ID Field: Enter your PWSID – –Submission Method Dropdown: “WEBFORM” – –Click Finished Step E – –Application will be verified and approved Step F – –Once approved, you’re my CDX page will have a link to DCTS; click link to enter DCTS

54. DCTS Quick Guide to Logging In for PWSs For more detailed information, refer to the DCTS Quick Guide http://www.epa.gov/ogwdw /disinfection/tools/pdfs/instr uctions_mdbp_dcts.pdfhttp://www.epa.gov/ogwdw /disinfection/tools/pdfs/instr uctions_mdbp_dcts.pdf Please send questions to: stage2mdbp@epa.gov stage2mdbp@epa.gov

55. Questions?

56. IDSE Tool Wizard Overview

57. IDSE Tool: Purpose Helps you determine which IDSE option is best for your system Guides you through templates, using the IDSE guidance manual excerpts to explain requirements Generate an electronic file for your system to submit and keep on file

58. IDSE Tool: Information The IDSE Tool is comprised of two modules – –The Wizard – –Plan/Report Entry

59. General Information - Wizard The Wizard – Walks you through a series of questions that will help you determine: – –If your system has any IDSE requirements – –Appropriate IDSE compliance option for your system – –The specific requirements for your system determined by its schedule and IDSE compliance option

60. IDSE Tool – CD Version EPA also developed a CD version of the IDSE Tool – –Target audience of IDSE Tool CD Version:   Systems that do not have access to the internet   Systems serving fewer than 10,000   Systems serving more than 10,000 may use the CD, but may need to get additional forms (e.g., to list all monitoring sites – –Limitations:   May not submit electronically   No pre-populated categories   Will not auto-generate monitoring tables

61. IDSE Tool Demonstration

62. IDSE Tool – CD Version To obtain the CD Version – –Visit the Stage 2 DBPR Web site: http://www.epa.gov/safewater/disinfection/t ools/tools-idse.htmlwww.epa.gov/safewater/disinfection/t ools/tools-idse.html – –Contact the EPA Warehouse: (202)260-3103 – –E-mail stage2mdbp@epa.gov

63. Questions?