Docstoc

STAGE 2 DISINFECTION BYPRODUCTS

Document Sample
STAGE 2 DISINFECTION BYPRODUCTS Powered By Docstoc
					  2009 WCHD and WESTCHESTER
COUNTY WATER SUPPLIERS’ MEETING
     STAGE 2
  DISINFECTION
BYPRODUCTS RULE
      (DBPR)
                  OVERVIEW
 Background
 Applicability
 Requirements
 Schedule
              BACKGROUND
 Finalized by EPA Dec. 2005
 Disinfection Byproducts
 Stage 1 DBPR
     Monitoring: Plant, Source and Population
     Compliance Calculation: Running Annual
      Average
 Stage   2 DBPR
     Monitoring: Source and Population
          APPLICABILITY
 Very Small System (VSS) Waivers
 40/30 Certification
 Schedules and CDS
         40/30 Certification and
              VSS Waiver
 Waiver Effective Immediately
 Waived from Initial Distribution System
  Evaluation (IDSE)

 MustContinue Compliance with Stage
 1 DBPR until Stage 2 DBPR Compliance
 begins
            STAGE 2 DBPR
 Purpose
 Distribution   System Evaluation
 Monitoring
 40/30Certification and Very Small System
  Waiver
         REQUIREMENTS
 Population
 Monitoring
 IDSEReport
 Compliance Monitoring Plan
 Compliance Monitoring
                     SCHEDULE
SCH     SYS.       40/30      Complete     IDSE        Comp.
       Serving   Cert/Mon.    SM/SSS       Report     Monitoring
                 Plan/VSS
                  Waiver
1     ≥100,000 Oct 1,        Sep 30,     Jan 1, 2009 Apr. 1,
               2006          2008                    2012
2     50,000-    Apr 1,      Mar 31,     July 1,     Oct. 1,
      99,999     2007        2009        2009        2012
3     10,000-    Oct 1,      Sep 30,     Jan 1, 2010 Oct. 1,
      49,999     2007        2009                    2013
4     <10,000    Apr 1,      Mar 31,     July 1,     Oct. 1,
                 2008        2010        2010        2013
             Stage 2 Compliance Monitoring
                       Locations
                                               Distribution system monitoring location
              Population                                                                  Existing
 Source                    Monitoring     Total per     Highest         Highest
                 size                                                                   subpart L
water type                 frequency1    monitoring     TTHM             HAA5
               category                                                                compliance
                                           period2     locations       locations
                                                                                         locations
Subpart H    <500          per year               2                1               1
             500–3,300     per quarter            2                1               1
             3,301–9,999   per quarter            2                1               1
             10,000–
                           per quarter            4                2               1             1
             49,999
             50,000–
                           per quarter            8                3               3             2
             249,999
             250,000–
                           per quarter           12                5               4             3
             999,999
             1,000,000–
                           per quarter           16                6               6             4
             4,999,999
             ≥5,000,000    per quarter           20                8               7             5
         Stage 2 Compliance Monitoring
                   Locations

                                             Distribution system monitoring location
             Population                                                                 Existing
 Source                   Monitoring     Total per    Highest         Highest
                size                                                                  subpart L
water type                frequency1    monitoring    TTHM             HAA5
              category                                                               compliance
                                          period2    locations       locations
                                                                                       locations
Ground       <500         per year               2               1               1
water        500–9,999    per year               2               1               1
             10,000–
                          per quarter            4               2               1             1
             99,999
             100,000–
                          per quarter            6               3               2             1
             499,999
             ≥500,000     per quarter            8               3               3             2
             IDSE Report Contents:
       Stage 2 Compliance Monitoring
                 Locations
   8-Step Site Selection Protocol
1 Select the location with the highest TTHM LRAA          1st highest
                                                          TTHM site
2 Select the location with the highest HAA5 LRAA          1st highest
                                                          HAA5 site
3 For subpart H systems: Select the existing Stage 1      1st Stage 1
  average residence time compliance monitoring            DBPR site
  location with the highest HAA5 LRAA

    For ground water systems: Select the existing Stage
    1 maximum residence time compliance monitoring
    location with the highest HAA5 LRAA

    Skip this step if you have no more Stage 1 sites
              IDSE Report Contents:
       Stage 2 Compliance Monitoring
                 Locations
   8-Step Site Selection Protocol (con’t)

    4 Select the location with the next highest   2nd highest
      TTHM LRAA                                   TTHM site


    5 Select the location with the next highest   3rd highest
      TTHM LRAA                                   TTHM site


    6 Select the location with the next highest   2nd
      HAA5 LRAA                                   highest
                                                  HAA5 site
            IDSE Report Contents:
       Stage 2 Compliance Monitoring
                 Locations
   8-Step Site Selection Protocol (con’t)
7 For subpart H systems: Select the remaining            2nd Stage 1
  existing Stage 1 average residence time                DBPR site
  compliance monitoring location with the highest
  TTHM LRAA
  For ground water systems: Select the remaining
  existing Stage 1 maximum residence time
  compliance monitoring location with the highest
  TTHM LRAA
  Skip this step if you have no more Stage 1
8 Select the remaining location with the next highest    3rd highest
  HAA5 LRAA                                              HAA5 site
Go back to Step 1 of this protocol and repeat the steps until you have
selected the required number of total sites.
            SUMMARY
 DBPR  Requirements
 Schedule/Time Line
 Monitoring Plan
 Monitoring
 Long Term 2 Enhanced
Surface Water Treatment
         Rule
         LT2
              Overview
 Purpose  & Background
 LT2 Overview
 Schedules & Timeline
 Process
 Bin Classification
 Implementation
 Summary
      Purpose & Background
 Finalizedby EPA Dec. 2005
 Improve Public Health Protection
 Cryptosporidium
 Current Surface Water Treatment Rule
 Who Does It Apply To?
           LT2 Overview
 What is LT2?
 Source Water Monitoring
 Screening Procedure for Small Systems
 Treatment for Higher Risk Systems
 Crypto Inactivation
 Uncovered Storage Facilities
           Schedules & Timeline
Schedule         Criteria          Schedule       Treatment
                                                 Installation
   1       System or CDS serving      1       Apr 1, 2012
           ≥100,000 people

   2       System or CDS serving      2       Oct 1, 2012
           50,000-99,999 people

   3       System or CDS serving      3       Oct 1, 2013
           10,000-49,999 people

   4       System or CDS serving      4       Oct 1, 2014
           ≤10,000
     Process Implementation
 Source Water Monitoring
 Bin Classification
 Treatment
 Implementation
 Second Round of Source Water
  Monitoring
                  Bin Classification
 Based on Source Water Monitoring
 Treatment Requirements

Bin    Conventional       Direct filtration     Slow sand or       Alternative
         filtration                            diatomaceous         filtration
        treatment                              earth filtration   technologies
        (including
        softening)

 1     No additional       No additional       No additional      No additional
        treatment           treatment           treatment          treatment
 2    1-log treatment     1.5-log treatment   1-log treatment          (1)
 3    2-log treatment     2.5-log treatment   2-log treatment          (2)
 4    2.5-log treatment   3-log treatment     2.5-log treatment        (3)
            SCHEDULE 4
<  10,000
 Letter of intent
 Treatment Installation by October 1, 2014
              Summary
 Source Water Monitoring
 Bin Classification
 Treatment
Ground Water Rule
     (GWR)
                 Ground Water Rule
• Finalized by EPA Oct. 2006
• Rule Implementation: December 1, 2009
• Purpose:
       Identify PWS with poor source water quality
       Identify significant deficiencies during sanitary
        surveys
       Systems that are identified may be required to:
         •   Correct all significant deficiencies
         •   Replace source
         •   Remove contaminant sources
         •   Install treatment to fully protect customers
            GWR Applicability
Applies to PWS with:
• Ground water sources
• Consecutive systems receiving ground water
• Mixed SW & GW systems – if any GW source doesn’t
  not mix with SW prior to treatment
Does not Apply to PWS with:
• GWUDI
• Mixed SW & GW systems – if all GW source is mixed
  with SW prior to treatment
     Key Provisions of the GWR

•   Source Water Monitoring
•   Sanitary Surveys of all GWS
•   Corrective Actions for Significant
    Deficiencies and Fecal Contamination
•   Compliance Monitoring
      Source Water Monitoring
            Provisions
New Sources:
•  Assessment Monitoring Required –
   source water assessment monitoring to
   identify high risk systems
Existing Sources:
•  Triggered Monitoring – systems that do
   not provide 99.99% (4-log) treatment and
   have a positive total coliform sample
   under the Total Coliform Rule
          Assessment Monitoring

•   Evaluation of source water over time to
    see whether fecal contamination is present
       Frequency and length of study to be
        determined by State
       Fecal Indicator to be determined by State
       What Triggers the GWR?

•   Significant deficiencies observed during
    sanitary survey
•   Total Coliform positive sample in
    distribution
•   New systems
    GWR Triggered Monitoring Due to
      Total Coliform in Distribution

•   Repeat sample location within 24 hours
•   Sample all raw water at source
        If fecal contamination is confirmed
          • 5 additional samples from same source within 24
            hours
          • Any of the 5 samples are positive – must comply
            with Treatment Technique Requirements and
            Compliance Monitoring
       Public Notification for Fecal
          Indicator at Source


•   Must provide Tier 1 Public Notification
•   All Consecutive Systems must issue Tier 1
    Public Notification
 GWR Trigger – Significant
Sanitary Survey Deficiencies
     8 Critical Elements of a Sanitary Survey
1.   Source
2.   Treatment
3.   Distribution System
4.   Finished Water Storage
5.   Pumps, Pump Facilities, and Controls
6.   Monitoring, Reporting, and Data Verification
7.   System Management and Operation
8.   Operator Compliance with State Requirements
     Sanitary Survey Follow-Up

•   LHD sends notice to system of need for
    corrective action
•   Issue Enforcement Action
•   Administrative Hearing
•   Setup milestones for compliance
    New Systems Coming Online
     After November 30, 2009
•   Must be designed to achieve 4-log virus
    inactivation and begin compliance
    monitoring within 30 days of activation
       Will be capable of meeting GWR
        requirements if they are triggered into it
•   Includes existing systems that make
    significant modifications to treatment
    process or expansion to system
          Compliance Monitoring
•   Applies only to Systems that provide 4-
    log virus removal
       Inactivation
       Removal
       State-approved combination of 4-log
        inactivation and removal
•   State must be notified in writing of
    intention to begin compliance monitoring
•   Compliance monitoring avoids triggered
    source water monitoring
    Compliance Monitoring (Cont’d)
       Chemical Disinfectant
•   Systems serving >3300 people
       Continuous monitoring of disinfectant residual
       Maintain a State determined minimum
        residual
       Record lowest daily residual value


•   Continuous monitoring equipment failure
       Grab sample every 4 hours
       Repair equipment within 14 days
    Compliance Monitoring (Cont’d)
       Chemical Disinfectant
•   System serving ≤ 3300 people
     Take daily grab samples during peak hourly
      flow
    OR
     Meet all requirements for systems serving

      >3300 people
•   If disinfectant residual falls below State
    minimum
       Take sample every 4 hours until residual
        meets required level
           Early Implementation
              Requirements
All PWS must comply prior to Dec 1, 2009
• Install raw water taps at all individual GW
  sources
• Evaluate system zones
• Install water meter on system
• Notification Protocol for Consecutive Systems
     Be able to notify supplier to sample sources
      within 24 hours
     Be able to notify other consecutive supplies of
      Tier 1 Public Notification
 CROSS CONNECTION
    CONTROL AND
BACKFLOW PREVENTION

  PROTECTING YOUR WATER
                TOPICS
   OVERVIEW

   DESIGN , APPROVAL OF PLANS &
    INSTALLATION

   TESTING & MAINTENANCE

   RECORD KEEPING

   RECOMMENDATIONS
           LEGAL AUTHORITY

   STATE LAW/REGULATION-NYSDOH

    -LAW: Public Health Law Sec. 225(10)
    -REGULATION: Subpart 5-1.31 of the State
                      Sanitary Code
       “all public water systems are Required
        to have a Cross-Connection Program”
     -REGULATION: NYS Department of State
                      Plumbing code of NYS
    PUBLIC WATER SYSTEM

 COMMUNITY   WATER SYSTEMS

 NON-COMMUNITY


 NON-TRANSIENT


 TRANSIENT
       BACKFLOW PREVENTION
        DEVICES DESIGN AND
           INSTALLATION
   TYPES OF DEVICES

   PREPARING PLANS FOR APPROVAL OF INSTALLATION AND
    SUBMITTING
    TO WCDH FOR REVIEW & APPROVAL

   ENGINEER’S REVIEW COMMENTS

   WATER PURVEYOR ROLE WHEN
    PLANS ARE SUBMITTED AND AFTER APPROVAL

   WCDH CERTIFICATE OF APPROVAL & CONDITIONS
    OF APPROVAL
       FORM DOH-1013
 BACKFLOW   PREVENTION DEVICE
 TESTING

 COMPLETION   OF Part A & Part B

 SUBMISSION   OF FORM TO WCDH

 MAINTENANCE
     WCDH RESPONSIBILITY
   PROVIDE GUIDANCE TO WATER
    PURVEYORS

   TO ENSURE COMPLIANCE WITH NYSDOH
    AND WCDH SANITARY CODES

   ISSUE VIOLATIONS

   SANITARY SURVEYS (checking for cross
    connections)
          WATER SUPPLIER
          RESPONSIBILITY
   TO ASSURE THAT ALL CROSS
    CONNECTIONS ARE PROTECTED

   TO DETERMINE THE DEGREE OF HAZARD
    FROM A FACILITY TO THE WATER SYSTEM
    AND TO REQUIRE THAT A BACKFLOW
    PREVENTER DEVICE BE INSTALLED,
    TESTED, OPERATED AND MAINTAINED AND
    THAT ADEQUATE RECORDS OF
    MAINTENANCE AND REPAIRS ARE KEPT
        RECOMMENDATIONS
   EFFECTIVE RECORD KEEPING TO DEMONSTRATE
    COMPLIANCE

   ASSIGN CROSS-CONNECTION RESPONSIBILITY TO
    KEY PERSONNEL

   NOTIFY AND EDUCATE CUSTOMERS ON THE NEED
    FOR SYSTEM PROTECTION WHEN BACKFLOW
    DEVICES ARE REQUIRED

   DEVELOP A EFFECIVE BF PROGRAM FOR THE
    ELIMINATION OR PROTECTION OF ALL CROSS
    CONNECTIONS
Changes to Lead and
 Copper Rule (LCR)
  (Effective 2010?)
              Applicability


   Applies to Community and Non Community
    Non Transient PWS



   Not applicable to Transient Non Community
    PWS
          GENERAL CHANGES

   Applicable to all Community and Non Transient
    Non Community Systems

     Monitoring Requirements
      Allow Systems with low lead and copper tap
       levels to immediately reduce lead and
       copper tap monitoring and Water Quality
       Parameter (WQP) monitoring to once every
       3 years
   Allow NTNCWS and certain CWS not having
    enough taps where water has stood
    motionless for at least 6 hours, to collect a
    sample from the tap with the longest
    standing time.

   Flexibility in time of year when systems can
    conduct reduced monitoring

   Permit some ground water systems to limit
    Biweekly entry point monitoring to
    representative locations
   Grant monitoring waivers to small systems
    with plumbing free of lead and copper
    containing material

   Clarify and provide flexibility in sampling site
    requirements

   Permits Health Department to invalidate tap
    samples (conditions apply)
   Clarify number of samples required

   Clarify number of sites from which samples should
    be collected

   Clarifies need for a 9 year monitoring waiver for
    “Lead-Free” systems

   Modifies definitions for monitoring and compliance
    periods “All samples must be taken within the same
    calendar year”

   New Reduced monitoring requirements – prevents
    water systems to remain on reduced monitoring
    when in non-compliance with WQP levels
       Public Education

         Lead or Copper exceedance

         Allow NTNCWS and special case CWS to use alternative
          language

         Flexibility in mode of delivery (especially those supplies
          serving 3,300 or fewer people)

         Message content

         How materials are delivered

         Timeframe of delivery

         Delivery requirements which include additional organizations

         PWS to provide results to customers whose tap water was
          sampled, along with public awareness information
       Analytical Methods

       Reporting and Record Keeping
        Requirements
         Remove redundant reporting requirements
         Revise record keeping


       Customer Awareness
         Notification of sampling results
         Public Education Requirements
      CHANGES TO SYSTEMS WITH
            TREATMENT
 Demonstration        of Optimal Corrosion Control
     Community and Non community Non Transient
      PWS with Treatment

            Continue to maintain and operate existing corrosion
             control
     Systems deemed optimized
            Monitor for lead and copper tap samples once every
             3 years
            Meet the copper action level
       State designated Water Quality Parameters
               Way in which compliance is determined


   Lead Service Line Replacement Requirement

       Applicability - Systems subject to lead service line
        replacement
               Requires replacement of the portion of lead service line that is
                owned by PWS
               Notify residents of the potential for temporary increases in lead
                levels and measure they can take to reduce lead levels


       Reconsideration of lead service lines deemed
        replaced through testing
 Water   Treatment Requirements

     Advanced notification and approval
      requirement for water systems that intend to
      make any change in water treatment or add a
      new source of water that could affect the
      system’s optimal corrosion control
      Annual Water Quality Report
              (AWQR)
 Applicable   to Community PWS

     Requires lead in drinking water educational
      statement in all AWQRs

     PWS written education statement (alternate)

     Requires specific public ed language to be
      included in AWQR
       Additional Information


   EPA’s “Minor Revisions” (Jan. 12, 2000)
     • www.epa.gov/EPA-WATER/2000/January/Day-
       12/w3.pdf

   “Short Term Revisions” (October 10, 2007)
     • www.epa.gov/fedrgstr/EPA-
       WATER/2007/October/Day-10/w19432.pdf
RADIONUCLIDES
 MONITORING
  (Refresher)
                Radionuclides Monitoring

   Applicable Regulations

       US-EPA 40 CFR Part 9, 141, 142

       New York State Sanitary Code Part 5, Subpart 5-1,
        Section 5-1, Table 7

   Who is required to do the monitoring?

       All Community Public Water Supplies (CPWS)

   Who is not required to the monitoring?

       Non Community Public Water Supplies
       Consecutive Community Public Water Supplies
        RADIONUCLIDES MONITORING (cont’d)

              Initial Monitoring Requirement


   Four Consecutive Quarter Monitoring

       Gross Alpha (Gα)

       Radium 226 (Ra-226)

       Radium 228 (Ra-228)

       Uranium     (U)
          Radionuclides Monitoring (cont’d)

   Maximum Contaminant Level (MCL)

       Gα including Ra-226   15   pCi/L

       Ra-226 & Ra-228       5    pCi/L

       Uranium               30   ug/L (20 pCi/L)
              Radionuclides Monitoring (cont’d)
           Result Analysis and Schedule Determination



   Monitoring Results of Radionuclides (Gross α, Rad-226, Rad-228, U)


        Below detection limit                    → 9 year

        Detection Limit ≤ Results ≤ ½ MCL        → 6 year

        ½ MCL value < Results ≤ MCL              → 3 year

        Results > MCL                            → Quarterly
          Radionuclides Monitoring (cont’d)
            Compliance Schedule Determination



   Compliance based on Source Monitoring

   If there are multiple sources; compliance schedule will be
    determined by the value of the contaminant which project the
    shortest monitoring schedule

   If one or more of the multiple sources exceed MCL; entry point
    sampling will be required and compliance schedule will be
    determined by the entry point result
          Radionuclides Monitoring (cont’d)

   Statistics
      Total 100 CPWS

        • 77 CPWS required to conduct Radiological monitoring

               18 systems on 9 year schedule

               46 systems on 6 year schedule

               9 systems on 3 year schedule

               4 systems on quarterly schedule

        • Based on the review of 3 yearly sample results submissions, 1
          system required increase monitoring to quarterly schedule
Drinking Water State
  Revolving Fund
          DRINKING WATER STATE
         REVOLVNG FUND (DWSRF)
   Result of 1998 Safe Drinking Water Act (SWDA) EPA allotted
    grant funding to each State based on each state proportional
    share based on infrastructure needs survey & assessment

   NYS – 2009 Allotment $86,811,000.00        2010 Tentative
    Allotment $96,724,000.00

   Program Administered by the NYS Environmental Facilities
    Corporation (NYSEFC) & NYS Department of Health (NYSDOH)

   Provides subsidized low interest rate financing and limited grants
    for construction of eligible water system projects.
   For communities with demonstrated financial interest rates can be
    reduced to as low as 0%

   Severe financial hardship – Financial hardship grants may be
    available thru SWDA

   Eligible Drinking Water Systems:
       Community Water Systems: Municipal and Privately Owned
       Non-Profit, Non Community Water Systems

   More information available at:
        www.NYSEFC.Org/Home/Index.ASP?page=15
                    Additional Funding
   Appropriation under the American Recovery and Reinvestment Act
    (ARRA) of 2009

   Short term goal to identify projects that can achieve ARRA goal to
    commence construction activity within 120 days of enactment.

   Long term goal to commit all funds of ARRA to projects to be under
    contract for construction by February 17, 2010.

   ARRA requires 20% of funds to be utilized for projects that
    incorporate green infrastructures, energy efficiency, water efficiency,
    and/or environmentally innovative activity.
    TYPES OF ELIBGIBLE PROJECTS:
   Rehabilitation or development of new drinking water sources to
    replace contaminated supplies

   Installation or upgrade of treatment facilities to ensure compliance
    with State and Federal Drinking Water Standards or
    Treatment/Performance Criteria

   Installation or upgrade of storage facilities, including finished water
    reservoirs to prevent microbiological contamination or to provide
    adequate delivery pressures

   Installation or replacement of transmission and distribution mains to
    prevent contamination caused by leaks or breaks.

   Purchase of a portion of another system if the purchase is part of a
    consolidation plan to bring the system(s) into compliance.

   Capital investments to improve the security of Drinking Water
    Systems
           APPLICATION PROCESS
Two Step Process:

1.   Pre-application form to NYSDOH

          Project Information
          Contact Information
          Project Schedule
          Project Cost Estimate

Above is used to list and rank projects in the Intended Use
Plan (IUP)
2.     A complete DWSRF Financial Application to NYSEFC
       publicly or privately owned facilities

            Complete series of forms/application/information
            Financial Information – long term
            Construction Costs
            Economic & Financial Data

     Application forms and more information available at:

www.NYSEFC.Org/Home/Index.ASP?page=15
ONGOING ISSUES
ONGOING ISSUES
Sanitary Surveys
Microbiological Monitoring and
 Operations Reports
Monitoring of GWUDI Supplies
Vulnerability Assessment
        SANITARY SURVEYS
 Sample  Schedules
 Security Checklist
 PWS Representatives
     DO Treatment
     DO Distribution
     Cross Connection Control Program
      Designated Representative
MICROBIOLOGICAL MONITORING
  AND OPERATIONS REPORTS
 MICROBIOLOGICAL MONITORING
   AND OPERATIONS REPORTS
 Sampling    Plans
     Site Selection Criteria
     Approved Plans


 Monitoring   Requirements
     Number of Samples
     Time of Sampling
 MICROBIOLOGICAL MONITORING
   AND OPERATIONS REPORTS
 Operations   Reports
     Minimum Requirements
     Submission Deadline
MONITORING OF GWUDI
     SUPPLIES
      MONITORING OF GWUDI
           SUPPLIES

 Microbiological   Monitoring
     Sampling Frequency
     Number of Samples
     MONITORING OF GWUDI
          SUPPLIES
 Disinfection/Disinfectants   Byproducts

      Monitoring Requirements
Population      Routine     Reduced
>10,000        4/Qtr/TP    1/Qtr/TP
500-9,999      1/Qtr/TP    1/Yr/TP
<500           1/Yr/TP      1/Yr/TP
      MONITORING OF GWUDI
           SUPPLIES
 Turbidity   Monitoring
     Unfiltered Systems
         Continuous/Every 4 hours at source
         1 sample/day at entry point (C)
         1 sample/year at entry point (NC)
     Filtered Systems
         Continuous monitoring of effluent
         5 samples/week in distribution
VULNERABILITY ASSESSMENTS
   Required VA and ERP
   VA Certifications
   Security Checklist
   Updated VA Review
   Additional Information
    EPA-Water Security-Vulnerability Assessment
http:/cfpub.epa.gov/safewater/watersecurity/home.cfm?program
SDWIS-Web AND DRINKING
    WATER WATCH
      SDWIS-Web AND DRINKING
          WATER WATCH
 SDWIS
     Safe Drinking Water Information System
         Versions
 Previous
 SDWIS-Web
     Availability
     Impact
      SDWIS-Web AND DRINKING
          WATER WATCH
 Drinking   Water Watch
     Availability
     Types of Information
     Access
 Laboratory   Data Input
     Sampling Sites
     Impact
DESIGNATED OPERATOR IN
  RESPOSIBLE CHARGE
  DESIGNATED OPERATOR IN
   RESPONSIBLE CHARGE
 Current   situation
     PWS requiring Designated Operators
     Systems Classifications
      ~ IA, IIA, IB, IIB, C, D
     Operator Grades Levels
      ~ IA, IIA, IB, IIB, C, D
     Enforcement
  DESIGNATED OPERATOR IN
   RESPONSIBLE CHARGE
 Enforcement   changes
     Operator Grades
     Operator Grade Hierarchy
     Effective Date
  2009 WCHD and WESTCHESTER
COUNTY WATER SUPPLIERS’ MEETING