Stage 1 and 2 Disinfection Byproduct Rule
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Stage 1 and 2 Disinfection Byproduct Rule presented by: Joseph Munson Outline • Introduction to Disinfection Byproducts • Stage 1 & 2 Overview • Initial Distribution System Evaluation (IDSE) Options • Stage 2 Compliance • DCTS • IDSE Tool Public Health & Disinfection Disinfectants: • Kill or inactivate disease-causing microorganisms • React with substances naturally in water to form harmful DBPs • Produce negative health effects when present in excessive levels How Are DBPs Formed? Added Disinfectant Precursor in Water NOM Bromide + Chlorine Chloramines Chlorine Dioxide Ozone DBP TTHM = HAA5 Chlorite Bromate Health Effects • Disinfectants • Byproducts: (in large doses): − Cancer − Eye and nose − Liver problems irritation − Kidney problems − Stomach discomfort − Central nervous − Anemia system problems − Other acute short- − Anemia term health effects − Reproductive problems A Delicate Balance Risk: microbial contamination vs. DBP formation EPA’s solution: control health risks from microbials, disinfectants, and Microbials DBP’s DBPs Result: M-DBP Suite of rules Stage 1 & 2 DBPR Overview Stage 1 & 2 DBPR Overview • Stage 1 − Applied to all community and nontransient noncommunity water systems that add a chemical disinfectant. − 221 systems in South Dakota are complying with Stage 1 regulations. • Stage 2 − Will apply to all community and nontransient noncommunity water systems that add a chemical disinfectant or that purchase water with an added chemical disinfectant. − 403 systems in South Dakota will have to comply with Stage 2 regulations. The requirements that apply to each system depend on treatment process and type of source water. Population-Based Monitoring and Scheduling • Stage 1 DBPR – Scheduling based on source water type and population served – Monitoring based on source water type, population served, and number of treatment plants/wells • Stage 2 DBPR – Scheduling based on source water type, population served, and population of the largest system in combined distribution system (CDS) – Monitoring based on source water type and population served (excluding CDS) Combined Distribution Systems (CDSs) • All systems in a CDS (i.e., wholesalers, consecutive systems) must comply with Stage 2 DBPR requirements on the same schedule – Compliance date is based on the population of the largest system in the CDS – Largest system is not necessarily the wholesaler • EPA or state has discretion to determine CDS – Emergency or seasonal connections Consecutive Systems • Must comply with IDSE requirements • Must conduct Stage 2 DBPR TTHM and HAA5 compliance monitoring • Must comply with the Stage 1 DBPR requirements for chlorine and chloramines Compliance Calculation & Reporting • Stage 1 − Calculate compliance at the end of every quarter in which the system monitors using the Running Annual Average (RAA) of results from the last 12 months and compare to MCL • Stage2 − Calculate compliance at the end of every quarter in which the system monitors using a Locational Running Annual Average (LRAA). Systems must report a LRAA for every site they sample at and each LRAA must be below the MCL. • Compliance Reporting for Stage 1 & 2 − Within 10 days of the end of each quarter in which samples are taken, report RAA or LRAA, MCL violations, and information about samples to the state. − Consecutive systems must begin complying with the Stage 1 DBPR requirements for chlorine and chloramines beginning April 1, 2009. Each system must submit a quarterly chlorine residual to the state within 10 days of the end if each quarter. Stage 1 & 2 DBPR MRDL & MCL • MRDLs Disinfectant MRDL Chlorine 4.0 mg/L Chloramines 4.0 mg/L Chlorine Dioxide 0.8 mg/L • MCLs Disinfection Byproduct MCL TTHM 0.080 mg/L HAA5 0.060 mg/L Bromate 0.010 mg/L Chlorite 1.0 mg/L Initial Distribution System Evaluation (IDSE) Options IDSE Options 1 2 3 4 VSS 40/30 Standard System Waiver Certification Monitoring Specific Study Existing Data Only New and Existing Data Choose Stage 2 TTHM/HAA5 Sites for Compliance Conduct Stage 2 Compliance Monitoring LRAA IDSE Implementation Timeline Submit 40/30 Submit IDSE Report Certification, SM, Complete SM or (only systems Sch. Systems Serving: SSS Plan, or SSS By: conducting SM or receive VSS SSS) by: Waiver 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 < 10,000 Apr. 1, 2008 Mar. 31, 2010 July 1, 2010 Schedule for systems in a combined distribution system is based on that of the largest system in the combined distribution system Very Small System (VSS) Waivers IDSE Options Eligibility Criteria • Systems must – Serve fewer than 500 people – Have taken TTHM and HAA5 samples Reduced monitoring acceptable Operational data acceptable • 137 systems out of an eligible 243 systems in South Dakota have received their VSS Waiver Note: EPA or the state may deny a VSS Waiver for any reason, even if system meets all eligibility criteria VSS Waivers • Waivers effective immediately − No application necessary − Systems must meet all criteria • EPA or the state can require Standard Monitoring or System Specific Study • VSS Waiver is only a waiver from additional IDSE activities − No Standard Monitoring or System Specific Study Plan − No IDSE Report • Continue compliance with Stage 1 DBPR until Stage 2 DBPR compliance begins – Complete a monitoring plan for the Stage 2 DBPR 40/30 Certification Eligibility Criteria • Systems must have Stage 1 DBPR data equivalent to 8 quarters worth of data: − No individual sample can have exceeded: 0.040 mg/L for TTHM 0.030 mg/L for HAA5 − No TTHM or HAA5 monitoring violations − For schedule 3 and 4 systems data can not be before January 1, 2005 • Approximately 88 systems in South Dakota will be eligible for a 40/30 Certification Note: EPA or the state may deny the certification for any reason, even if system meets all eligibility criteria Operational Data • EPA or the state may allow systems to use operational data to qualify for certification – Should be equivalent to Stage 1 DBPR data • Considerations – Samples taken and analyzed by approved methods at a certified lab – Adequate number of sample sites for system size – Samples taken at appropriate locations (average to maximum residence time) – Samples taken at appropriate frequency and during month of warmest water temperature Submitting a 40/30 Letter • Once a system has collected a sufficient amount of data it can prepare a 40/30 Certification Letter and submit it to the EPA: – Electronically (through IDSE tool) – Hard-copy (through mail) USEPA-IPMC PO Box 98 Dayton, OH 45401-0098 Example 40/30 Certification Letter System Information PWS Name_____________________ PWS ID:_______________________ Street Address:__________________ City, State, Zip:_________________ Population Served:_______________ Source Water Type: Ground Subpart H System Type: CWS NTNCWS Combined Distribution System: Wholesale Consecutive Neither Contact Person Name: _______________________Title: ____________________ Phone Number:__________________Fax Number (if available):____________ Email Address (if available):_______________________ Certification I hereby certify that each individual Stage 1 DBPR compliance sample collected from ________ to _______ was less than or equal to 0.040 mg/L for TTHM and 0.030 mg/L for HAA5. I understand that to be eligible, each individual sample must be equal to or below these values. I also certify that this PWS collected all required Stage 1 samples and did not have any monitoring violations during this time period. Signature:_________________ Date:______________________ Standard Monitoring Standard Monitoring IDSE Steps 1 Select Standard Monitoring Locations 2 Prepare and Submit Standard Monitoring Plan EPA or the state approves the Standard Monitoring Plan 3 Conduct Standard Monitoring Select Stage 2 DBPR 4 compliance monitoring locations 5 Prepare and Submit IDSE report IDSE Schedule for Standard Monitoring Submit Systems Complete Sch. Submit Plan IDSE Serving Monitoring Report 1 > 100,000 10/1/2006 9/30/2008 1/1/2009 50,000 – 2 4/1/2007 3/31/2009 7/1/2009 99,999 10,000 – 3 10/1/2007 9/30/2009 1/1/2010 49,999 4 < 10,000 4/1/2008 3/31/2010 7/1/2010 Schedule for systems in a combined distribution system is based on that of largest system in the combined distribution system Required Components of Standard Monitoring Plan • Distribution system schematic – Entry points, sources, and storage facilities – Locations and dates of proposed Standard Monitoring sites – Locations and dates of Stage 1 DBPR monitoring sites • Population served • Source water type • Justification of Standard Monitoring sites – Must include a summary of data used to justify selection of Standard Monitoring sites Standard Monitoring Requirements • What, where, and how often do I monitor? – Samples Collected Dual sample set (both TTHM and HAA5) collected at all locations – Monitoring Locations High TTHM levels High HAA5 levels Average Residence Time Near Entry Points – Number of sites Based on system’s source water type and population served – Monitoring Frequency 1, 4, or 6 monitoring periods during the year at each location Number based on population served and source type TTHM and HAA5 Standard Monitoring (1) • For groundwater systems or systems that purchase groundwater Frequency Total Near High High Population ART (in year) Sites EP TTHM HAA5 < 500 consecutive 1 (during 2 1 - 1 - peak < 500 non- historical 2 - - 1 1 consecutive month)(2) 500-9,999 2 - - 1 1 4 (every 90 10,000 – 99,999 6 1 1 2 2 days) 100,000-499,999 8 1 1 3 3 (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. TTHM and HAA5 Standard Monitoring (1) • For Subpart H systems and systems that purchase Subpart H water High High Population Frequency Total Near EP ART TTHM HAA5 <500 consecutive 1 (during 2 1 - 1 - peak <500 non-consecutive historical 2 - - 1 1 month)(2) 500-3,300 consecutive 2 1 - 1 - 500-3,300 4 (every 90 2 - - 1 1 non-consecutive days) 3,301-9,999 4 - 1 2 1 10,000-49,999 6 (every 60 8 1 2 3 2 days) 50,000- 249,999 16 3 4 5 4 Standard Monitoring Site Selection – Justification • Plan must include a justification for the selection of sites to be sampled during Standard Monitoring • Data sources and tools – Distribution system maps – Water quality data – Distribution system operating data Final “Selected” Sites • Some site selection will be obvious – Near entry point • Others will require professional judgment – Consider geographic representation – Consider hydraulic representation – Consider areas fed by sources with higher DBP precursors – Use sites that “multi-task” – Consider accessibility Submitting Standard Monitoring Plan • Once the system has collected and analyzed its information, it must prepare the plan and submit it to EPA or the state – Electronically (through IDSE tool) – Hard-copy (mail to IPMC address) • Must include required information System Specific Study (SSS) Stage 2 Compliance Monitoring Schedule System Start Stage 2 Compliance Sch. Serving: Monitoring By: 1 > 100,000 April 1, 2010 2 50,000 –99,999 Oct. 1, 2012 3 10,000 –49,999 Oct. 1, 2013 Oct 1, 2013 4 < 10,000 Oct 1, 2014* * Date for systems that were required to conduct Crypto monitoring under LT2 Questions? Information Processing & Management Center (IPMC) and Data Collection & Tracking System (DCTS) Information Processing and Management Center (IPMC) • What is the IPMC? − It’s a centralized location to process hard copy Stage 2 DBPR & LT2ESWTR submissions • What is the Goal of the IPMC? − To conduct administrative tasks such as data entry and mail distribution for the Regions and states − Have one mailing address that would process all the Stage 2 DBPR & LT2ESWTR submissions What can be submitted to the IPMC? • For Stage 2 DBPR: – 40/30 Certifications – Standard Monitoring Plans – System Specific Study Plans Extensive Data Hydraulic Modeling • IDSE Reports IPMC Contact Information • The IPMC will receive, sort, scan, & perform data entry for Stage 2 DBPR and LT2ESWTR submissions into the DCTS. Mailing Address: Fax Number: Stage 2 DBPR & 937-586-6557 LT2ESWTR IPMC P O Box 98 E-mail Address: Dayton, OH 45401 firstname.lastname@example.org Data Collection & Tracking System (DCTS) What is the DCTS? – It’s a database that will track and store Stage 2 DBPR and LT2ESWTR early implementation submissions – For Stage 2 DBPR, gives you access to the online IDSE tool Develop and submit your 40/30 Certification or IDSE Plan or Report online Accessing the IDSE Tool • There are many ways to access the IDSE Tool – Online CDX username and password required Submit information electronically to EPA – CD Version Download or request from EPA warehouse E-mail, fax, or mail information to EPA – Hard Copy Template From IDSE Guidance Manual Fill in template by hand Mail information to EPA Accessing the IDSE Tool Both the online and the CD version of the IDSE Tool have access to the Wizard and the Plan/Report Entry feature – Wizard determines which IDSE option is best for the system – IDSE Plan/Report Entry feature creates custom forms for the selected IDSE option and helps the system complete electronic forms Accessing DCTS • There are two ways to register for DCTS: – Using a CRK key EPA began distributing CRK keys to PWSs in Summer 2006 (according to system schedule) – Via the CDX Web site Access Request Process for Individuals With a CRK Key • What is a CRK Key? – User name and password that allows first time users to login to the DCTS if the user does not already have access through other applications • Who will receive a CRK Key? – Administrative users (the first user associated with an organization) will receive the CRK Key in the mail – Do not change provided user name to ensure pre-registration works! User Approval within DCTS • Administrative users in each organization will be responsible for approving all standard users – Admin user must be registered before others can use the DCTS for their organization – Some admin users may be linked to more than one organization (e.g., DCTS users with multiple PWSs) Commonly used by those who work for a PWS organization CRK Access Go to: http://cdx.epa.gov/preregistration What if I Did Not Receive a CRK Letter and Need to Register? Access Request Process We recommend that you use the Registration Guide (sent with email handout) Go to https://cdx.epa.gov Access Request Process Steps for New DCTS Users with No CRK and No Previous Interaction with CDX: • Step A – Apply for access via EPA’s CDX Web site • Step B – Read and sign the warning notice, privacy statement, and terms and conditions – Fill out User and Organization information • Step C – Select: “LT2ESWTR: LT2ESWTR, Stage 2 DBPR, and IDSE Plan/Report Entry” from the list of CDX applications Add Program: Step C for All Users Access Request Process Steps for New DCTS Users with No CRK: • Step D: Select – Role Dropdown Menu: “A Submitter” – Program ID Type: “Standard” – ID Field: Enter your PWSID – Submission Method Dropdown: “WEBFORM” – Click Finished • Step E – Application will be verified and approved • Step F – Once approved, you’re my CDX page will have a link to DCTS; click link to enter DCTS DCTS Quick Guide to Logging In for PWSs • For more detailed information, refer to the DCTS Quick Guide • http://www.epa.gov/ogwdw /disinfection/tools/pdfs/instr uctions_mdbp_dcts.pdf • Please send questions to: email@example.com Questions? IDSE Tool Wizard Overview IDSE Tool: Purpose • Helps you determine which IDSE option is best for your system • Guides you through templates, using the IDSE guidance manual excerpts to explain requirements • Generate an electronic file for your system to submit and keep on file IDSE Tool: Information • The IDSE Tool is comprised of two modules – The Wizard – Plan/Report Entry General Information - Wizard • The Wizard – Walks you through a series of questions that will help you determine: – If your system has any IDSE requirements – Appropriate IDSE compliance option for your system – The specific requirements for your system determined by its schedule and IDSE compliance option IDSE Tool – CD Version • EPA also developed a CD version of the IDSE Tool – Target audience of IDSE Tool CD Version: Systems that do not have access to the internet Systems serving fewer than 10,000 Systems serving more than 10,000 may use the CD, but may need to get additional forms (e.g., to list all monitoring sites – Limitations: May not submit electronically No pre-populated categories Will not auto-generate monitoring tables IDSE Tool Demonstration IDSE Tool – CD Version • To obtain the CD Version – Visit the Stage 2 DBPR Web site: http://www.epa.gov/safewater/disinfection/t ools/tools-idse.html – Contact the EPA Warehouse: (202)260-3103 – E-mail firstname.lastname@example.org Questions?