1. PUBLIC WATER SYSTEM PLAN and EXCEPTION REVIEW
Plan Review Team
David T. Smith, P.E.
Technical Review and Oversight Team
Erin Guerra, P.E.
Plan and Technical Review Section
Water Supply Division

2. Why Submit Plans? Law Public Health and Safety
Plan Review Team Mission: To ensure that public water system construction meets minimum standard public health and operational safety design criteria in compliance with federal and state statute and good engineering practices.
Law
Texas Health & Safety Code
Federal Safe Drinking Water Act

3. HEALTH and SAFETY …this is why we require review and maintenance!
Ready for Pump
Replacement?
This slide contains pictures of equipment in need of maintenance or replacement.

4. Who Submits Plans? ALL Public Water Systems*
Professional Engineers (P.E.) Licensed in the State of Texas
ALL Public Water Systems*
Cities, Districts, Non-profit or For-Profit, Wholesale or Retail, or Privately Owned Water Systems
* That have 15 service connections or serve 25 or more individuals at least 60 days out of a year.

5. When Do We Submit Plans?
BEFORE STARTING CONSTRUCTION:
No person may begin construction on a new public water system before receiving written approval of plans and specifications. §290.39(h)(1)
IF SIGNIFICANT CHANGE TO EXISTING SYSTEM IS PLANNED:
Significant changes shall not be instituted without prior approval ….§290.39(j)

6. What’s A Significant Change?
Potential Health Hazard: §290.39(j)(1)(B)&(C)
Increase or Decrease in Capacity: §290.39(j)(1)(A)
~Distribution
~Treatment
~Production
~Pressure
~Storage
This slide contains a picture of ground storage tanks. Potential Health hazard would include treatment changes.

7. Significant Changes… Distribution Capacity (measured in connections)
Distribution expansion, waterlines (in connections) # of new connections <10% total existing connections and does not affect the ability to comply with capacity requirements or involves interconnection with another public water system
290.39(j)(1)(d)

8. More Significant Changes…
Disinfection §290.39(j)(1)(B)
Disinfectant
Application point
Monitoring point
Residual §290.39(j)(1)(C)
This slide contains a schematic of a surface water treatment plant.

9. Significant Changes ANY OTHER MATERIAL CHANGES
specified by TCEQ. §290.39(j)(1)(E)

10. Plans & Specs NOT Required
CHANGES NOT SIGNIFICANT?
Waterline additions less than 10% of the total connections
Waterlines subject to ordinance review
A) ORDINANCE: Copy of local ordinance or statute requiring submittal to another state agency with its own internal review staff. §290.39(j)(2)(B)
B) CERTIFICATION: Written 290 compliance certification by internal staff P.E.
C) NOTIFICATION: Letter of notification to TCEQ. §290.39(j)(2)(B)

11. What To Submit? Written Notification §290.39(h)(2) and/or Cover Letter
Submittal Form §290.39(h)(1)(2)
Engineering Report §290.39(e)(1) New system, SWTP, or deficiencies
Engineering Plans and Technical Specifications §290.39(j)(2)(B)
Business Plan §290.39(f)
for Privately owned new public water systems
addresses are considered confidential

12. Plan Submittal Form Must use unaltered TCEQ form only
Use latest revision of the form
Can be obtained from TCEQ Webpage
Sign and seal the form
This slide contains a picture of the TCEQ Plan Review Submittal Form.

13. ENGINEERING DRAWING Sign, seal, and date each page SEAL
This slide contains a picture of an engineer’s drawing, showing the placement of the engineer’s seal.
SEAL

14. CONSTRUCTION SPECIFICATIONS
BOUND WITH COVER PAGE
SIGNED, SEALED & DATED
This slide contains an example of construction specifications submitted to the TCEQ.

15. What Else Is Submitted?
Submit and Receive Approval for Following Prior to Plant Startup and PRIOR to Plan Review Submittal:
Exception Request for any changes from rule requirements
Pilot study
Change in source
New filtration rate
Alternative process (not conventional filtration)
CT* Study – 90 days prior / SWTP
_______________________________________
*C = disinfectant residual concentration, T = time

16. Mail: Deliver: Where Do We Send Plans? Plan Review Team - MC-159
Texas Commission on Environmental Quality
P.O. Box 13087
Austin, TX
Deliver:
12015 Park Circle, Bldg. F, 3rd. Floor
Austin, TX 78753

17. How Are Plans Processed?
RECEIVE ~ 180 Plans/Month
Given a Log Number and Entered into WUD database
Administrative Review
Assigned to Plan Reviewer
Reviewed by Engineering Staff* in order received
The average is the 3 year average for 2015, 2016 and 2017.

18. TYPES OF PROJECTS 2018
This slide contains a chart showing the types of projects received by TCEQ in 2018: wells, 21%; ground water treatment plants, 11%; surface water treatment plants, 2%; Reverse Osmosis – 1% waterlines, 37%; and other, 28%. Other includes tanks not at a designated plant, generators, disinfection, corrosion control treatment and so on.

19. http://www.tceq.state.Texas.gov/drinking water/planrev.html
WEB SITE
water/planrev.html
New: Surface Water Checklists
This slide shows the Plan Review page on the TCEQ website. In addition to checklists with what rules are reviewed on a particular submittal, we also have construction notes for typical facility upgrades

20. Process Related Plans- Reviewed by Technical Review and Oversight Team
Disinfection:
Chlorination/Chloramination
Chlorine Dioxide
Ozonation UV
Treatment:
Conventional filtration
Package plants
Membranes
Ion Exchange
Innovative Technologies
Each project reviewed on a site specific basis

21. Exceptions: Proposing Another Way to Meet the Intent of the Rules
Plan & Technical Review Section
Technical Review and Oversight Team
Erin Guerra, P.E.
May 2019

22. Scope
Learn the purpose of the FBRR and the procedural requirements of the PWS
Learn the procedural requirements to request an exception to propose another way to meet the intent of the rules under 30 TAC 290, Subchapter D

23. Where do Exceptions Come From?
Allowed as described in 30 TAC § (l)
Each request is considered on an individual basis.
Must demonstrate that the exception will not compromise the public health or degrade the service or water quality.
Any granted exception can be revised or revoked.
As a condition of granting the exception the TCEQ may establish site-specific design, operation, maintenance, and reporting requirements for systems.

24. 2018 - Exceptions Received per Rule Section

25. Procedural Requirements
When are exceptions allowed?
Who can submit an exception request?
What is required in the exception submittal?
When do you submit exception requests?
Where do you send exception requests?

26. When are Exceptions Allowed?
If a public water system (PWS) does not meet a TCEQ design standard, they may request an exception by proposing another way it can meet the intent of the rules.
There are no design standards in the TCEQ regulations for these types of treatments.
This Photo by Unknown Author is licensed under CC BY-NC-SA

27. Who Can Submit Exceptions?
Public Water Systems and their representatives
For almost any rule between §
Professional Engineers licensed in Texas
Pilot study reports - §290.42(g)
Alternative Capacity Requirement requests for alternatives to elevated storage - §290.45(g)(5)

28. What is required in an Exception submittal?
TCEQ
Signed cover letter
Proposed alternative, explanation, supporting documentation

29. What Else Is Submitted?
Submit and Receive Approval for Following Prior to Plant Startup and PRIOR to Plan Review Submittal
Exception Request for any changes from rule requirements – 90 to 100 days
Pilot study
Change in source
New filtration rate
Alternative process (not conventional filtration)
CT* Study – 90 days prior / SWTP
_______________________________________
*C = disinfectant residual concentration, T = time

30. When do you submit Exception Requests?
Before the PWS is locked into a course of action that will result in a deviation from the rules.
To comply in response to an alleged violation noted during a Comprehensive Compliance Inspection (CCI).
Before submitting engineering plans and specifications for review and approval.

31. Where Do You Submit Exception Requests?
Technical Review and Oversight Team
Plan and Technical Review Section, MC -159
Texas Commission on Environmental Quality
P.O. Box 13087
Austin, TX

32. Process Related Plans Disinfection: Treatment: Conventional filtration
Blending Chlorine & Chloramines
Chlorine Dioxide
Ozone
Ultraviolet
Treatment:
Conventional filtration
Package plants
Membranes
Ion Exchange
Innovative Technologies
Each project reviewed on a site specific basis

33. Help with Exception Submittals
Used by the public and TCEQ Staff
Available on TCEQ Website
Updated in 2018
Staff Guidance Documents
Documentation required
Checklists

34. How Long Does It Take TCEQ to Review the Request?
Each exception request is reviewed to ensure that, if granted, the PWS will still deliver safe drinking water to its customers at adequate pressures.
Type
Timeframe
Exceptions
100 days
ACRs
90 days
Expedited requests are considered but must have a very good reason for the request.

35. Last Things About Exceptions
Any granted exception can be revised or revoked.
As a condition of granting the exception the TCEQ may establish site-specific design, operation, maintenance, and reporting requirements for systems.

36. Financial, Managerial, & Technical (FMT) Assistance
If you operate a water or wastewater system and would like to arrange for free financial, managerial, or technical assistance, contact our Financial, Managerial and Technical (FMT) program team:
(512)

37. Small Business & Local Government Assistance
Free confidential hotline

38. Water Supply Mainline: (512) 239-4691
Questions?
Water Supply Mainline: (512)
Plan Review Website
Exception Website -
Water Supply General Box: