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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 stage2mdbp@epa.gov
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:
stage2mdbp@epa.gov
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 stage2mdbp@epa.gov
Questions?
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