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Regulatory Update

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Title: Regulatory Update


1
Regulatory Update
  • Silver Falls Conference 2006

DHS Drinking Water Program
2
Types 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

3
Routine 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
4
If 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

5
If 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

6
Repeat 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.

7
Surface 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.

8
Surface 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).

9
Surface 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).

10
LT2/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.

11
LT2ESWTR (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)

12
LT2ESWTR - 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
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14
LT2ESWTR 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.

15
Monitoring 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

17
Grandfathering 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

18
Monitoring 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

19
First 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.
20
Calculating 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

21
Determining 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

22
Reporting 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

23
Additional 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
24
LT2 Treatment Toolbox
Inactivation
Additional filtration
Source
Pre filtration
Treatment Performance
25
LT2ESWTR 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.

26
EPAs 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

27
LT2 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
28
LT2ESWTR 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.

29
Stage 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.

30
What 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.

31
Stage 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).

32
DBP 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
33
Stage 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.

34
Stage 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

35
Concerns 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

36
Major 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)

37
Stage 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

38
IDSE 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

39
IDSE 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

40
IDSE 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.

41
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
42
Stage 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

43
Stage 2 Monitoring Schedule
44
EPAs 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

45
IDSE 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
46
Arsenic
  • 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.

47
Arsenic
  • 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.

48
Radionuclides 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

49
Groundwater 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.

50
Groundwater 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.

51
Groundwater 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.

52
NTNC 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.

53
GWUDI 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

54
Source 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.

55
Drinking 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.)
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