Stage 2 DBP Rule Distributionrelated Rule

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Stage 2 DBP RuleDistribution-related Rule

• Julie W. Roney
• Technical Assistance and Outreach
• Drinking Water Branch
• Kentucky Division of Water

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Presentation Outline

• Brief overview of the rule
• Regulatory timeframe
• Working with Federal EPA
• New electronic database

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• Overview

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Background

• Signed into law on December 15, 2005
• Published in Federal Register on January 4, 2006
• Affects surface, ground and purchasing systems
  Everybody plays
• Will take effect based on 4 population categories
• gt100,000
• 50,000 99,999
• 10,000 49,999
• lt10,000

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Background

• Stage 2
• Builds upon existing rules
• Should identify better, more representative THM
  and HAA sites
• Improve public health by reducing exposure to
  DBPs
• Must still comply with all requirements of Stage
  1 until Stage 2 compliance begins

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Combined Distribution System

• Combined Distribution System (CDS) concept
• Look at entire area water is distributed from a
  water treatment plant
• Take into account emergency connections,
  direction of flow, amount supplied
• EPA made first effort at this but it was not
  correct
• DWB has since revised the CDS listing and has
  been told it will be accepted by EPA
• KEY ISSUE When a system begins monitoring is
  determined by the system with the largest
  population within the CDS (not all populations
  added together)
• Example Dawson Springs
• Example Audience

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Combined Distribution System

• Consecutive systems
• Will be conducting their own monitoring under
  this rule
• May lack enough THM/HAA data to make decisions
• Producer may have a THM/HAA sample point in a
  consecutive system as a maximum point
• May have data from prior to Stage 2 rule when
  some consecutive systems did THMs under KY regs
• Receives water that already has THM/HAAs in it
• Will necessitate that producers and purchasers
  talk to each other

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Combined Distribution System

• Stage 2 (and LT2) are population-based and not
  plant based
• Example Surface water plant with 2 water plants
  serving 31,000 people
• Under existing rules would sample/test 2 times
  because had 2 plants
• Now would sample once based upon 31,000 people

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Example of CDS
Purchaser 6500
Producer 10,000
Purchaser 300
Purchaser 2000
Purchaser 51,000
Everyone in Schedule 2
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Example of CDS
Everyone on Schedule 3
Purchaser 12,000
Producer 7500
Producer 3500
Producer 8600
Purchaser 300
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Monitoring Requirements

• Initial Distribution System Evaluation (IDSE)
• Compliance Monitoring
• Based on sites chosen as a result of the IDSE
• Move to Locational Running Annual Averages
• Compliance based on each site not sites averaged
  together
• No change to THM or HAA MCLs
• No change to the TOC requirements

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IDSE

• An evaluation to determine locations with
  representative high THM and HAA concentrations in
  the distribution system
• Must take THM and HAA at same time
• Must have one monitoring period during warmest
  water temperature or peak historical month for
  THMs or HAAs
• Will vary system to system

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IDSE Applicability

• Must conduct an IDSE if your system is a
• community water system that uses a primary or
  residual disinfectant other than UV light or
  delivers water that has been treated with a
  primary or residual disinfectant other than UV
  light or
• nontransient, noncommunity water system that
  serves at least 10,000 people and uses a primary
  or residual disinfectant other than UV light or
  delivers water that has been treated with a
  primary or residual disinfectant
• None in KY

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IDSE Options

• Four IDSE options
• Standard Monitoring Plan
• System Specific Study (primarily an hydraulic
  model)
• 40/30 Certification
• Very Small System (lt500K) Waiver

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Standard Monitoring Plan

• Sampling above and beyond current compliance
  sites
• Number of samples based on a chart in the regs
• Approximately twice the number of compliance
  samples
• Example Surface water 10,000-49,999 (both
  producer and true purchaser) takes 8 samples
  every 60 days with 1 near the entry point, 2
  average residence, 3 high THM and 2 HAAs
• Example Purchaser lt500 (if no waiver) takes 2
  samples once a year at the entry point and high
  THM
• Example Groundwater 500-9,999 (both producer
  and purchaser) takes 2 samples every 90 days at a
  high THM and high HAA
• EPA developing an IDSE Tool to assist with
  these
• Out by March/April 2006

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Standard Monitoring Plan

• A standard monitoring plan must be developed and
  approved
• Following completion of the monitoring must do an
  IDSE Report
• Basically the report will designate new THM and
  HAA sites for Stage 2 monitoring

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System Specific Study

• Can be done 2 ways
• Existing monitoring results
• High number of samples taken before the IDSE
  compliance date (5 years prior)
• Example 10,000-49,999 must have had 24 sites
  that result in 144 THMs and 144 HAAs
• Wont see any of this type of SSS
• Modeling
• Extended period water quality model with
  specifics outlined in rule and Guidance Manual
• Does include 1 round of monitoring outlined in
  the Standard Monitoring Plan
• Will go beyond what most systems currently have
  as an hydraulic model
• Will see some of these

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40/30 Certification

• No IDSE required if all compliance THM and HAA
  samples are less than 40 ug/L and 30 ug/L
  respectively for a 2-year period
• Must submit request for 40/30 certification and
  provide the data
• The 2 year consecutive period is dependent upon
  population
• Example 10,000-49,999 40/30 timeframe is 2
  years beginning no later than January 2005

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Very Small System Waiver

• Only for those systems less than 500 in
  population
• Must have taken THM and HAA compliance samples (1
  per year in warmest month at maximum retention)
• State can accept this site as your Stage 2 site
• KY DWB intends to get as many of the lt500 systems
  on THM/HAA sampling this summer in order to use
  this option

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Choosing New Monitoring Sites

• From the IDSE sampling must choose new THM/HAA
  sites
• Chart and process in regulation that outlines how
  to choose samples
• Based on population size and source water
• Combination of highest IDSE THM and HAA sites
  plus existing Stage 1 sites
• Must monitor every 90 days
• Must monitor once in peak historical month
• Must do a compliance monitoring plan
• This can be part of the IDSE

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Stage 2 Compliance

• Locational Running Annual Averages
• Compliance based on each site not sites averaged
  together
• Sites are those chosen from the IDSE monitoring
• Sample every 90 days
• THMs and HAAs must be taken together (paired
  samples)

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Compliance

• Best Available Technologies
• For systems with treatment plants
• Enhanced coagulation or enhanced softening plus
  GAC10 or
• Nanofiltration or
• GAC20
• For consecutive (purchasing systems)
• Improved distribution system and storage tank
  management to reduce residence time plus the use
  of chloramines (chloramines for systems gt10K)
• Systems with treatment plants should use the
  consecutive system BAT as well

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Operational Evaluation Levels (OEL)

• Initially was called Significant Exceedances
• Is a projection of what the next quarters
  compliance might be
• Sum of 2 previous quarters 2(current quarter)
• 4
• equals an average that is compared to the MCLs
• If this value exceeds the MCL must do a report
  and submit to state within 90 days
• Must include an evaluation of the plant and
  distribution system practices

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• Timeline

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Stage 2 Timeline
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40/30 Time Frames
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• Working with Federal EPA

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Role of Federal EPA

• Federal EPA in Washington will be handling the
  early implementation activities for all systems
  greater than 10K
• New electronic databases
• Information Processing and Management Center
  (IPMC)
• Data Collection and Tracking System
• Receive and approve IDSE plans
• Receive and approve 40/30 certifications
• Receive and approve System Specific Studies
• Receive and approve IDSE report
• Receive and approve selected LRAA sample sites

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Role of States

• States will have access to the Federal database
  and will be highly involved in the decisions made
  on systems gt10K
• States will do the bulk of the review and
  approval for Stage 2 for all size systems
• Databases will serve as a clearinghouse
• States will handle the lt10K systems

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Role of the Water Systems

• Water systems will need access to the data system
• Change contact information
• Track approval of reports and submissions

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QUESTIONS??? COMMENTS???

• Julie W. Roney, Supervisor
• Technical Assistance and Outreach
• Drinking Water Branch
• 502/564-3410
• Julie.Roney_at_ky.gov
• www.epa.gov/safewater