What Your System Needs to Meet the Stage 2 Regulation

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What Your System Needs to Meet the Stage 2
Regulation

• Presented at the
• 50th Annual KWWOA Conference
• Louisville KY
• March 27, 2007

2
Stage 2 Overview

• Stage 2 covers the next set of requirements for
  disinfection by-products
• Early implementation activities
• 4 Schedules in a Combined Distribution System
  concept
• Initial Distribution System Evaluation
• Compliance determinations
• Location running annual averages
• 90 day sampling
• Paired samples

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Schedule Reminder
4
Early Implementation--IDSE

• The IDSE is a one-year special study of the
  distribution system to find areas that may/will
  have elevated THMs and HAAs
• 4 options
• Standard Monitoring Plan (most common)
• System Specific Study (detailed hydraulic model)
• 40/30 Certification (groundwater systems)
• Very Small System Waiver (lt500 population with
  THM/HAA data)

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Compliance Monitoring

• New sites based on the IDSE and Stage 1 sites (if
  applicable)
• Locational Running Annual Averages
• All sites must meet the MCLs
• Samples taken every 90 days
• One monitoring period must be in the month of
  highest THM/HAA or warmest water
• Paired samples

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Getting Ready for Stage 2--General

• Look at this in 2 phases
• IDSE
• Compliance
• Look at this as a Distribution System Rule
• Distribution operators You asked for morehere
  it is!
• There will still be a focus on TOC removal but
  the emphasis of this rule moves to the
  distribution system

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Getting Ready for Stage 2--General

• Get a copy of the regulation
• Go to the end and read the rule language
• The first part is the preamble that explains why
  EPA did what they did
• Download/copy those parts of the Guidance Manuals
  that are applicable
• Chapters
• Forms
• Examples

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Getting Ready for Stage 2--General

• Go to training
• Group training
• Workshops
• Webcasts
• Individual water system

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Getting Ready for Stage 2--IDSE

• Evaluate your options
• Very Small System WaiverAsk yourself
• Is your population less than 500?
• Use DWB multiplication factor or census data
• Do you have compliance THM and HAA data?
• Will need lab data
• 40/30 CertificationAsk yourself
• Are all of my sites less than 0.040 mg/L for THMs
  and 0.030 mg/L for HAAs for the time period
  specified?
• Will need to fill out the 40/30 Certification
  Form and submit
• Will need lab data to submit

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Getting Ready for Stage 2--IDSE

• Evaluate your options
• System Specific StudyAsk yourself (and maybe
  your engineers)
• Do I have a very detailed, calibrated model of my
  system that meets all the requirements of Stage
  2?
• Or does your engineer have this? Can I get a
  copy?
• Do I understand the model?
• If I have a model, can it be refined to meet the
  Stage 2 requirements and how long will that take?
• Standard Monitoring Plan
• If you answered NO to all the above, you will
  be doing a Standard Monitoring Plan

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Getting Ready for Stage 2--SMP

• Preparing to do the Standard Monitoring Plan
• NOTE You can do this yourselfits not that
  hard
• You will need some assistance and some
  information

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TTHM and HAA5 Standard Monitoring(1)

• For groundwater systems or systems that purchase
  groundwater

(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.
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TTHM and HAA5 Standard Monitoring(1)

• For surface water systems and systems that
  purchase surface water

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Getting Ready for Stage 2--SMP

• IDSE Assistance must come from
• Distribution system operators
• Water plant operators
• Maintenance personnel
• Billing personnel
• Engineers
• Drinking Water Branch (other DOW) staff
• Water systems must overcome kingdoms
• Plants vs. Distribution
• Producers vs. Purchasers

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Getting Ready for Stage 2--SMP

• IDSE Information comes from the distribution
  system
• Distribution maps
• Tanks, booster stations, master meters, water
  plants, bact sites, Stage 1 sites
• Water flow
• Flow in and around tanks
• Multiple tank flow patterns
• Water residence time
• Tanks
• Mains
• Water usage
• Meter and pump readings
• Booster stations
• Pump
• Disinfection

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Getting Ready for Stage 2--SMP

• IDSE Information can come from water quality data
• Chlorine residual data
• Compliance bacts
• MORs
• HPC data
• Stage 1 THM and HAA data
• Chemical data
• Tracer study

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Getting Ready for Stage 2--SMP

• Assistance (people) and information can all come
  together to help complete the IDSE
• Can also use EPAs electronic tools
• IDSE Wizard to help select which ISDE option
• IDSE Tool to actually prepare and submit your
  IDSE

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Getting Ready for Stage 2 SMP Submissions

• Early implementation means you will be dealing
  with Federal EPA and to a limited extent Region 4
  EPA
• KY wont have primacy for a few more years
• EPA has a new database to handle Stage 2
• Data Collection and Tracking System (DCTS)
• You will submit the IDSE either by hard copy
  (snail mail) to Dayton OH or electronically
  through the IDSE Tool or email
• KY reviews, approves, tracks submissions through
  the DCTS
• Limited involvement
• Computers and internet are becoming essential
  tools for water systems

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Getting Ready for Stage 2--Compliance

• The regulation gives water systems 3 years to get
  ready for compliance
• From the time you complete the IDSE and chose new
  compliance sites until compliance monitoring
  begins
• Once you know which sites will be used for
  compliance, begin working to get those under
  control
• Thats another presentation!

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Questions?? Comments??

• Julie W. Roney
• 502/564-3410
• Julie.Roney_at_ky.gov
• www.water.ky.gov/dw
• www.epa.gov/safewater/disinfection