Stage 1 and 2 Disinfection Byproduct Rule

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					       Stage 1 and 2
Disinfection Byproduct Rule

                   presented by:
                 Joseph Munson
• Introduction to Disinfection Byproducts
• Stage 1 & 2 Overview
• Initial Distribution System Evaluation
  (IDSE) Options
• Stage 2 Compliance
• IDSE Tool
   Public Health & Disinfection
   • Kill or inactivate
   • React with
     naturally in water
     to form harmful
   • Produce negative
     health effects
     when present in
     excessive levels
    How Are DBPs Formed?
                             Added Disinfectant
Precursor in Water

                     +             Chlorine
                                Chlorine Dioxide


      =               HAA5
            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
            A Delicate Balance
   Risk: microbial
    contamination vs.
    DBP formation
   EPA’s solution:
    control health risks
    from microbials,
    disinfectants, and
                           Microbials   DBP’s
   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

• 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

        The requirements that apply to each system depend on
        treatment process and type of source water.
   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
  – 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
  – 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
         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
            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)
                       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

        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,
• 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
   – 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):_______________________
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
         Systems                               Complete
Sch.                      Submit Plan                               IDSE
         Serving                               Monitoring
 1     > 100,000            10/1/2006          9/30/2008          1/1/2009
       50,000 –
 2                          4/1/2007           3/31/2009          7/1/2009
       10,000 –
 3                          10/1/2007          9/30/2009          1/1/2010
 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
   – 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
•   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                -
      < 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
   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
                     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           -
<500 non-consecutive
                         historical    2         -       -      1           1
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
  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
  – Use sites that “multi-task”
  – Consider accessibility
   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
                  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
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
  − 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
  P O Box 98                  E-mail Address:
  Dayton, OH 45401
    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
  – 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
      Commonly used by those who work for a PWS
         CRK Access
Go to:
What if I Did Not Receive
a CRK Letter and Need to
  Access Request Process
We recommend that you use the Registration
  Guide (sent with email handout)
Go to
 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
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

• Please send questions to:
IDSE Tool Wizard
   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

  – 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
  – 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
  IDSE Tool – CD Version

• To obtain the CD Version
  – Visit the Stage 2 DBPR Web site:
  – Contact the EPA Warehouse: (202)260-3103
  – E-mail