Title: Regulatory Update
1Regulatory Update
- Silver Falls Conference 2006
DHS Drinking Water Program
2Types of Coliform Samples
- Routine
- Representative of water that people are drinking
- Taken from a site on your coliform sample plan
- Repeat
- Taken after notification of positive routine
sample - Special
- Taken for systems own information to verify if
sample tap is good, from a pipeline after
construction, etc. - Not representative of water in entire system
- Does not need to be reported to DWP
3Routine Sampling
- Number of samples and frequency based on system
type and size
Community Systems Monthly samples based on population Monthly samples based on population Monthly samples based on population
Non-transient, Transient, State-Reg. Systems Groundwater Groundwater Surface water
Non-transient, Transient, State-Reg. Systems Population Served Population Served Monthly sampling based on population
Non-transient, Transient, State-Reg. Systems 1000 1 per quarter gt 1000 monthly Monthly sampling based on population
Population Samples per month
Up to 1,000 1
1,000 2,500 2
2,501 3,300 3
Etc. See rules or call DWP
4If Total Coliforms Are Present
- System must call the County or State DWP
- Repeat samples must be collected w/in 24 hrs of
notification of a positive routine sample - Number of Repeat samples required
- Systems taking 1 or less routine per month 4
- Systems taking 2 or more routines per month 3
5If Total Coliforms Are Present (cont.)
- Repeat Sample Locations
- One from the original tap
- One within 5 service connections upstream
- One within 5 service connections downstream
- If 4 repeats are required, one from another
location in the system, preferably at the source
6Repeat Sampling Results
- If all repeat samples are coliform negative,
problem is resolved - Just remember at least 5 routine samples must
be collected during the month following a
positive sample - If any of the repeat samples are coliform
positive, the system violates the total coliform
MCL - corrective action and public notice is
required - Invalidation of results is possible see rules.
7Surface Water Treatment Rules
- Interim Enhanced and Long Term 1 Enhanced Surface
Water Treatment Rules. - Applies to all public water systems that use
surface water or are designated as groundwater
under direct influence of surface water. - Systems gt 10,000 population began January, 2002
all others January, 2005.
8Surface Water Treatment Rules
- For conventional and direct filtration plants
- Lowers turbidity standard to 0.3 NTU in at least
95 of measurements taken from the combined
filter effluent- never to exceed 1 NTU. - Requires continuous monitoring of each filter
unit and establishes turbidity performance
triggers. When exceeded, requires follow-up
actions (filter assessments, additional
reporting, etc.). - Turbidity standards for slow sand, diatomaceous
earth, and alternative filtration technologies
stay the same (1.0 NTU in 95 with max of 5 NTU).
9Surface Water Treatment Rules
- Sets the MCLG at zero for cryptosporidium and a
99 (2-log) removal requirement. - WTPs are assumed to meet the removal requirement
if they are meeting the turbidity standard. - Cartridge filter manufacturers must demonstrate 2
log removal for crypto. All cartridge filters in
use must comply with 2 log removal requirements
by January 2007. - Systems with elevated levels of DBPs (TTHMs gt
0.064 mg/l or HAA5s gt 0.048 mg/l) are required to
evaluate their disinfection practices- develop a
disinfection profile from data collected for a
one year period (used to evaluate how changes
made to the disinfection process to lower DBPs
might affect pathogen inactivation).
10LT2/Stage 2 Rules
- Promulgated January 4 5, 2006
- Early implementation by EPA- contact Wendy
Marshall, EPA Region 10 at (206) 553-1890 or at
marshall.wendy_at_epa.gov - EPA Hotline (800) 426-4791.
- EPA Guidance materials available on-line at
- http//www.epa.gov/safewater/disinfection/stage2
- http//www.epa.gov/safewater/disinfection/lt2
- Water systems involved in early monitoring and
implementation have been contacted by letter
directly from EPA.
11LT2ESWTR (LT2)
- Promulgated January 5, 2006
- Utilities All Surface Water and GWUDI systems
- Purpose Reduce risks from surface water
pathogens (Cryptosporidium) - Notable Cryptosporidium Outbreaks
- Medford/Talent (1992)
- Milwaukee (1993)
- North Battleford, SK (2001)
- Seneca Lake Park, NY (2005)
- Northwest Wales (2005-2006)
12LT2ESWTR - Basics
- Steps
- Monitor Source Water
- Cryptosporidium and/or indicator levels
- Screening procedure for small systems
- Assign Treatment Bin 1, 2, 3, or 4
- Based on monitoring results
- Targets treatment for highest-risk
- Implement Treatment
- Based on the requirements of Bin
- Choose from Toolbox options
- Cover or Treat Uncovered reservoirs
13(No Transcript)
14LT2ESWTR Source Water Monitoring
- Systems initially monitor their water sources to
determine treatment requirements. This monitoring
involves two years of monthly sampling for
Cryptosporidium. - To reduce monitoring costs, small filtered water
systems (lt10,000) will first monitor for E.
coliwhich is less expensive to analyze than
Cryptosporidiumand will monitor for
Cryptosporidium only if their E. coli results
exceed specified concentration levels.
15Monitoring Systems gt10,000
- Filtered systems serving gt 10,000
- Monitor for Crypto, E. coli, and turbidity
- At least monthly for 24 months
- Unfiltered systems serving gt 10,000
- Monitor for Crypto only
- At least monthly for 24 months
16 Monitoring Systems lt10,000
- Filtered systems serving lt10,000
- E. coli monitoring once every 2 weeks for 12
months - Must monitor for Crypto if E. coli trigger level
is exceeded - Crypto monitoring
- Can be done in lieu of E. coli monitoring
- Must be done if systems fails to monitor for
E.Coli - Unfiltered systems serving lt10,000
- Monitor for Crypto
- 2/month for 12 months OR 1/ month for 24 months
17Grandfathering Data
- Can use previously collected data to comply with
initial monitoring requirements - Needs EPA approval
- E. coli and Crypto samples must meet data quality
and sampling location requirements of LT2 - Crypto samples collected at least each calendar
month on a regular schedule starting 1/99 or later
18Monitoring Avoidance
- Filtered systems that provide at least 5.5-log
Crypto treatment - Unfiltered systems that provide at least 3-log
Crypto treatment - Notify EPA no later than sampling schedule
submission deadline - Can stop sampling if system notifies EPA in
writing that they will install treatment by the
applicable treatment compliance date
19First Round Monitoring Deadlines
System Serving Submit Sample Schedule/Location Description, Intent to Grandfather, Intent to Install full treatment Begin Monitoring Submit Grandfathered Data (if applicable) Submit Bin Classification (Filtered) or Mean Crypto. Level (unfiltered)
gt 100,000 July 1, 2006 October 2006 Dec 1,2006 April 1, 2009
50,000 99,999 January 1, 2007 April 2007 June 1, 2007 October 1, 2009
10,000 49,999 January 1, 2008 April 2008 June 1, 2008 October 1, 2010
lt 10,000 monitor E. coli July 1, 2008 October 2008 Dec 1, 2008
lt10, 000 monitor Crypto January 1, 2010 April 2010 June 1, 2010 October 1, 2012
filtered systems only filtered systems
exceeding the E. coli trigger, do not monitor
for E. coli. and unfiltered systems.
20Calculating Bin ConcentrationFiltered Systems
- After initial monitoring, filtered systems
calculate Crypto bin concentration for each plant - Large systems based on two years of monitoring
- Small systems based on one year of monitoring
21Determining Bin Classification Filtered Systems
Only
Crypto Concentration Bin Classification
lt 0.075 oocysts/L 1
0.075 - lt 1.0 oocysts/L 2
1.0 - lt 3.0 oocysts/L 3
gt 3.0 oocysts/L 4
- Systems serving lt 10,000 not required to monitor
for Crypto automatically classified in Bin 1
22Reporting Bin Classification Filtered Systems
- Report classification to EPA no later than 6
months after completion of initial and second
round -
- Failure to comply with reporting requirements is
a treatment technique violation
23Additional Treatment Requirements
Filtration Type Filtration Type Filtration Type Filtration Type Filtration Type
Bin Conventional Direct Direct Slow sand or diatomaceous earth Alternative
1 No additional treatment No additional treatment No additional treatment No additional treatment No additional treatment
2 1-log 1-log 1.5-log 1-log Up to state
3 2-log 2-log 2.5-log 2-log Up to state
4 2.5-log 2.5-log 3-log 2.5-log Up to state
Most systems are expected to fall into Bin 1
24LT2 Treatment Toolbox
Inactivation
Additional filtration
Source
Pre filtration
Treatment Performance
25LT2ESWTR Uncovered Finished Water Reservoirs
- Systems that store treated water in open
reservoirs must either cover the reservoir or
treat the reservoir discharge to inactivate 4-log
virus, 3-log Giardia lamblia, and 2-log
Cryptosporidium. - Notify EPA of use of each facility no later than
April 1, 2008 - Comply or be on EPA-approved compliance schedule
no later than April 1, 2009 - These requirements are necessary to protect
against the contamination of water that occurs in
open reservoirs.
26EPAs Role LT2
- Dependent on when State applies for primacy
- Primacy application due January 5, 2008
- May apply for extension through January 5, 2010
- Notify systems/provide education
- Review and approve system monitoring
- Schedules, Intent to Treat, Grandfathered data
- Bin determinations
- Oversee uncovered reservoir requirements
- EPA Headquarters process submittals/data
- EPA Region 10 Enforcement
27LT2 Implementation Dates
Schedule Systems Serving Submit Source Water Sampling Schedule Begin Source Water Sampling Comply with Crypto Treatment
1 100,000 Jul 1, 2006 Oct 1, 2006 Apr 1, 2012
2 50,000-99,999 Jan 1, 2007 Apr 1, 2007 Oct 1, 2012
3 10,000-49,999 Jan 1, 2008 Apr 1, 2008 Oct 1, 2013
4 E. Coli lt 10,000 Jul 1, 2008 Oct 1, 2008 Oct 1, 2014
4 Crypto lt 10,000 Jan 1, 2010 Apr 1, 2010 Oct 1, 2014
28LT2ESWTR Disinfection Benchmarking
- If choosing Inactivation as a tool to comply
with additional treatment requirements, systems
must review their current level of microbial
treatment before making a significant change in
their disinfection practice. - This review will assist systems in maintaining
protection against microbial pathogens as they
take steps to reduce the formation of
disinfection byproducts under the Stage 2
Disinfection Byproducts Rule, which EPA is
finalizing along with the LT2ESWTR.
29Stage 1 Disinfectants/ Disinfection By-products
- Purpose is to limit exposure to disinfectants and
by-products formed with organics present in the
water. - Applies to CWS, NTNCWS with disinfectant
including purchasing systems beginning in 2004. - Monitoring for disinfectants, by-products
- TTHM MCL - 0.080 mg/L.
- HAA5 MCL - 0.060 mg/L.
- Bromate MCL 0.010 mg/L.
- Chlorite MCL 1.0 mg/L.
- Max residual disinfectant level, 4 mg/L.
30What are disinfection byproducts?
- Disinfection byproducts (DBPs) are compounds
formed when chlorine or other disinfectants used
in drinking water combine with organic matter
(OM). - These include Total Trihalomethane Compounds
(TTHMs) and Haloacetic Acid Compounds (HAA5s). - Potential health effects of long term exposures
to DBPs include adverse reproductive health
effects, increased risk of cancer, liver and/or
kidney disease.
31Stage 1 DBP Rule
- Paired samples taken from location(s)
representing maximum residence time in
distribution system at warmest time of the
monitoring period. - MCL based on running annual average.
- Reduced monitoring at lt50 for 2 years.
- Reduced monitoring at lt25 for 1 year.
- TOC lt4 mg/L for 1 year (SW).
32DBP Monitoring Frequency
System Type Routine Monitoring1 Reduced Monitoring
Surface Water Popn. 500 9,999 1 sample per plant2 per quarter 1 sample per plant per year
Surface Water Popn. lt 500 1 sample per plant per year No reduction
Groundwater Popn. lt 10,000 1 sample per plant per year 1 sample per plant per 3-year cycle (Jan 1 Dec 31)
1 TTHM/HAA5 should be sampled in month of warmest
temperature 2 A plant can be a treatment
facility, entry point, well or a wellfield
33Stage 1 DBP Rule
- Out of Compliance if running annual average
exceeds MCL. - Notify State/County within 48 hours.
- Notify customers within 30 days (Tier 2 public
notice) - Public notice must include specific health
effects language. - Treatment Technique for TOC removal required if
TOC gt 2 mg/L (surface sources). - All affected water systems must have a monitoring
plan completed and available for inspection.
34Stage 2 Disinfectants and Disinfection Byproducts
Rule
- Promulgated January 4, 2006
- Applies to
- all CWS and NTNCWS
- use primary or residual disinfectant other than
UV and consecutive systems that receive
disinfected water - Purpose
- Reduce potential risk associated with DBPs
- Provide increased public health protection and
equity - Build on existing Stage 1 DBP Rule
35Concerns Following Stage 1
- Compliance calculations
- System-wide Running Annual Average
- Monitoring locations
- Not necessarily sites with the highest DBP
- Consecutive Systems
- DBP monitoring not required by all States
36Major Stage 2 Requirements
- Initial Distribution System Evaluation (IDSE)
- All CWS and NTNCWS 10,000 population
- Stage 2 DBPR Compliance Monitoring
- Locational Running Annual Average (LRAA)
37Stage 2 DBPR IDSE
- Under the Stage 2 DBP rule, community systems
will conduct an evaluation of their distribution
systems, known as an Initial Distribution System
Evaluation (IDSE), to identify the locations with
high disinfection byproduct concentrations. - These locations will then be used by the systems
as the sampling sites for Stage 2 DBP rule
compliance monitoring. - IDSE Options
- Standard Monitoring System Specific Study
- 40/30 Certification Very Small System Waiver
38IDSE Options
- Qualify for Very Small System Waiver
- Systems serving lt500 people
- Must have TTHM and HAA5 monitoring data
- No further requirements under the IDSE
- Meet 40/30 Certification
- Within specified period
- all TTHM samples 40 µg/L (2-year period)
- all HAA5 samples 30 µg/L (2-year period)
- No Stage 1 monitoring violations
- No further requirements under the IDSE
39IDSE Options
- Conduct System Specific Study (SSS)
- Based on
- Earlier monitoring studies
- Distribution system hydraulic model
- Requires plan and IDSE report
- Conduct Standard Monitoring (SM)
- Based on
- One year of DBP monitoring at non-Stage 1 sites
- Requires plan and IDSE report
40IDSE Plan Report
- Submit plan to EPA for review and approval prior
to conducting IDSE - Plan will identify IDSE monitoring locations
expected to have high TTHMs/HAA5s - System will utilize maps, water quality data and
operational data to locate sites - The report identifies Stage 2 Compliance
Monitoring sites reports results.
41Implementation Timeline
Sch. Systems Serving Submit 40/30 Certification, SM, SSS Plan, or receive VSS Waiver By Complete SM or SSS By Submit IDSE Report by
1 100,000 Oct. 1, 2006 Sept. 30,2008 Jan. 1, 2009
2 50,000-99,999 Apr. 1, 2007 Mar. 31, 2009 July 1, 2009
3 10,000-49,999 Oct. 1, 2007 Sept. 30,2009 Jan. 1, 2010
4 lt 10,000 Apr. 1, 2008 Mar. 31, 2010 July 1, 2010
42Stage 2 Compliance Monitoring
- If systems submitted IDSE report
- At locations and months recommended in IDSE
report - If system has 40/30 certification, VSS waiver or
is a NTNCWS serving lt10,000 - At locations (i.e, those based on Stage 1
monitoring locations) and dates identified in
required monitoring plan
43Stage 2 Monitoring Schedule
44EPAs Role Stage 2
- Dependent on when State applies for primacy
- Primacy application due January 4, 2008
- May apply for extension through January 4, 2010
- Notify systems/provide education
- Determine combined distribution systems
- Review Standard Monitoring or System Specific
Study Plans - Review 40/30 certifications
- Issue VSS waivers
- Receive and possibly review IDSE reports
45IDSE Implementation Timeline
Sch. Systems Serving Submit 40/30 Certification, SM, SSS Plan, or receive VSS Waiver By Complete SM or SSS By Submit IDSE Report by
1 100,000 Oct. 1, 2006 Sept. 30,2008 Jan. 1, 2009
2 50,000-99,999 Apr. 1, 2007 Mar. 31, 2009 July 1, 2009
3 10,000-49,999 Oct. 1, 2007 Sept. 30,2009 Jan. 1, 2010
4 lt 10,000 Apr. 1, 2008 Mar. 31, 2010 July 1, 2010
46Arsenic
- New MCL of 0.010 mg/l- down from 0.05 mg/l-
running annual average. - Applies to CWS, NTNCWS, new MCL effective on
01/23/06. First monitoring period 2005 - 2007. - If sampled prior to 01/23/06, new MCL doesnt
apply until next compliance period (2008-10). - If sampled after 01/23/06 or in 2007 and exceed
the MCL, quarterly sampling is required and a
confirmation sample may be required. - If sampled after 01/23/06 or in 2007 and are
close to the MCL, may require a confirmation
sample.
47Arsenic
- Monitor with Inorganic Chemicals
- Monitoring reduction to every 9 years with three
results below the MCL- grandfathering allowed. - 60 groundwater systems in Oregon with at least
one result gt 0.010 mg/L in recent sampling. - Treatment there are thirteen BATs for arsenic
removal- source blending, adsorption, ion
exchange, reverse osmosis to name a few.
Consider waste disposal when choosing a treatment
method.
48Radionuclides Rule
- Rule applies to Community water systems only.
- Must monitor for gross alpha, radium 226, radium
228 and uranium. - Initial monitoring period is 2004 2007. Four
consecutive quarters must be sampled. - 2005 systems serving gt 300 people
- 2006 systems serving 100-299 people
- 2007 systems serving lt 100 people.
- If you collected one sample of all 4 contaminants
before 12/8/03, one sample substitutes for the
initial 4 quarterly samples. - Follow-up sampling is Every 9 years if no
detects - Every 6 years if lt ½ MCL
- Every 3 years if gt ½ MCL
49Groundwater Rule
- Applies to all public systems using groundwater.
- A sanitary survey is required for community water
systems every 3 years non-community water
systems every 5 years. - Correct identified sanitary defects- major
deficiencies. - List of major deficiencies found on DWP Website.
- Hydrogeologic sensitivity analysis is required.
- Source Water Assessments qualify.
- Fecal indicator monitoring of source water with a
history of coliform problems.
50Groundwater Rule
- Treat (disinfect) for bacteria and viruses if
there are uncorrected significant sanitary survey
deficiencies, if the source is sensitive, or the
source is contaminated. - EPA estimates that the Groundwater Rule will
effect 8 10 of the wells in the U.S. - Final rule is due to be promulgated by EPA
sometime between Summer and Fall 2006. - Compliance date- three years after promulgation.
51Groundwater Under Direct Influence of Surface
Water (GWUDI) NTNC TNC
- Evaluated 689 sources with possible hydraulic
connection to surface water based on results of
Source Water Assessments. - Sources were dismissed based one or more of the
following - Hand Pump Wells
- Surface water gt200 and drawing water from an
alluvial aquifer - No disinfection treatment and no detections of
coliform in the last 3 years or detections were
distribution related only. - Currently 245 sources will now be evaluated for
surface water influence.
52NTNC TNC GWUDI Requirements
- Once system is notified by mail that they must
evaluate their water source for GWUDI, they have
three options - Begin sampling monthly special raw water
coliform for a period of 2 years. - If any results are confirmed positive for total
coliform, the system must complete MPA testing. - If system misses 2 consecutive months or 3 months
out of the reporting year, the system must
complete MPA testing. - Collect a total of 2 Microscopic Particulate
Analyses (MPA) during high river stage (February
May) a minimum of 1 month apart. - Assume their source is GWUDI and install approved
treatment.
53GWUDI Challenges
- Test results will be sent to the Springfield
Office - Expecting high rate of non-compliance and
enforcement may be a low priority - High cost and effort associated with MPA testing
(250-375 each) and only two labs available for
analysis
54Source Water Assessments
- Source Water Assessments completed for all C,
NTNC, in July 2005. Handful of TNCs left to
complete. - SWAs for new systems will be completed based on
priority. - Updates for past SWAs are completed every 5 years
with the Sanitary Survey for C and NTNC Schools
or when a system begins protection strategies.
55Drinking Water Protection
- Assist systems with developing and implementing
protection strategies - Providing workshops for communities interested in
collaborative protection strategies - Continue to educate the public on drinking water
protection - Partnership with DHS, DEQ and OAWU
- DEQ - Integrate into watershed approach
- Coordinate/leverage
other programs and agencies (DEQs Tanks,
ODF private forestlands, County
planning, USFS, BLM, ODOT, ODA, SWCD,
Watershed councils, etc.)