Transcript Slide 1

Regulatory Update
Silver Falls Conference 2006
DHS Drinking Water Program
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 system’s 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
Routine Sampling
Number of samples and frequency
based on system type and size
Community
Systems
Monthly samples based on population*
Non-transient,
Transient, StateReg. Systems
Groundwater
Surface water
Population Served
Monthly
sampling
based on
population
≤1000 – 1
per quarter
> 1000
monthly*
* 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
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
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
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.
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 > 10,000 population began
January, 2002; all others January, 2005.
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).
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 > 0.064
mg/l or HAA5s > 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).
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
[email protected]
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.
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)
LT2ESWTR - Basics
Steps
1. Monitor Source Water
–
–
Cryptosporidium and/or indicator levels
Screening procedure for small systems
2. Assign Treatment “Bin” 1, 2, 3, or 4
–
–
Based on monitoring results
Targets treatment for highest-risk
3. Implement Treatment
–
–
Based on the requirements of Bin #
Choose from Toolbox options
4. Cover or Treat Uncovered reservoirs
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 (<10,000) will first monitor for E. coli–
which is less expensive to analyze than
Cryptosporidium–and will monitor for
Cryptosporidium only if their E. coli results
exceed specified concentration levels.
Monitoring Systems <10,000
• Filtered systems serving <10,000
– 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 <10,000
– Monitor for Crypto
– 2/month for 12 months OR 1/ month for 24 months
First Round Monitoring Deadlines
System Serving
Submit: Sample
Schedule/Location
Description, Intent
to Grandfather,
Intent to Install full
treatment
Begin
Monitoring
Submit
Grandfathere
d Data (if
applicable)
> 100,000
July 1, 2006
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
< 10,000 &
monitor E. coli*
July 1, 2008
<10, 000 &
monitor Crypto**
January 1, 2010
October 2006 Dec 1,2006
Submit Bin
Classification
(Filtered) or
Mean Crypto.
Level
(unfiltered)
April 1, 2009
October 2008 Dec 1, 2008
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.
Calculating Bin Concentration
Filtered 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
Determining Bin Classification
Filtered Systems Only
Crypto Concentration
Bin Classification
< 0.075 oocysts/L
1
0.075 - < 1.0 oocysts/L
2
1.0 - < 3.0 oocysts/L
3
> 3.0 oocysts/L
4
• Systems serving < 10,000 not required to monitor
for Crypto automatically classified in Bin 1
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
Additional Treatment
Requirements
Filtration Type
Bin
Conventional
1
Direct
Slow sand or Alternative
diatomaceous
earth
No additional treatment
2
1-log
1.5-log
1-log
Up to state
3
2-log
2.5-log
2-log
Up to state
4
2.5-log
3-log
2.5-log
Up to state
Most systems are expected to fall into Bin 1
LT2 Treatment: Toolbox
Source
Pre filtration
Watershed
control
Pre-sed
basin
w/coag.
Alt.
source/intake
relocation
2-stage lime
softening
Bank
filtration
Inactivation
Treatment
Performance
Combined
filter
Individual
filter
Demonstration
of Performance
UV
Ozone
Chlorine
dioxide
Additional
filtration
Bag filter
Cartridge
filter
Membrane
Second
stage filter
Slow sand
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.
EPA’s 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
LT2 Implementation Dates
Schedule
Systems
Serving
Submit Source
Water Sampling
Schedule
1
≥100,000
Jul 1, 2006
Oct 1, 2006 Apr 1, 2012
2
50,00099,999
Jan 1, 2007
Apr 1, 2007
Oct 1, 2012
3
10,00049,999
Jan 1, 2008
Apr 1, 2008
Oct 1, 2013
< 10,000
Jul 1, 2008
Oct 1, 2008
Oct 1, 2014
< 10,000
Jan 1, 2010
Apr 1, 2010
Oct 1, 2014
4
E. Coli
4
Crypto
Begin Source
Water
Sampling
Comply with
Crypto
Treatment
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.
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.
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.
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 <50% for 2 years.
– Reduced monitoring at <25% for 1 year.
– TOC <4 mg/L for 1 year (SW).
DBP Monitoring Frequency
System Type
Routine
Monitoring1
Surface Water
Popn. 500 – 9,999
Surface Water
Popn. < 500
Groundwater Popn.
< 10,000
1 sample per plant2
per quarter
1 sample per plant
per year
1 sample per plant
per year
1
Reduced
Monitoring
1 sample per plant
per year
No reduction
1 sample per plant
per 3-year cycle
(Jan 1 – Dec 31)
TTHM/HAA5 should be sampled in month of warmest temperature
2 A plant can be a treatment facility, entry point, well or a wellfield
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 > 2 mg/L (surface sources).
All affected water systems must have a
monitoring plan completed and available for
inspection.
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
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)
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
IDSE Options
• Qualify for Very Small System Waiver
– Systems serving <500 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
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
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.
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
≥100,00
0
Oct. 1, 2006
Sept.
30,2008
Jan. 1, 2009
2
50,00099,999
Apr. 1, 2007
Mar. 31,
2009
3
10,00049,999
Oct. 1, 2007
Sept.
30,2009
Jan. 1, 2010
4
<
10,000
Apr. 1, 2008
Mar. 31,
2010
July 1, 2010
July 1, 2009
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 <10,000
– At locations (i.e, those based on Stage 1
monitoring locations) and dates identified in
required monitoring plan
Stage 2 Monitoring Schedule
EPA’s 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
IDSE Implementation Timeline
Sch. Systems Submit 40/30
Serving: Certification, SM,
SSS Plan, or
receive VSS
Waiver By:
Complete SM Submit
or SSS By:
IDSE
Report by:
1
≥100,00 Oct. 1, 2006
0
Sept.
30,2008
Jan. 1, 2009
2
50,00099,999
Apr. 1, 2007
Mar. 31,
2009
July 1, 2009
3
10,00049,999
Oct. 1, 2007
Sept.
30,2009
Jan. 1, 2010
4
<
10,000
Apr. 1, 2008
Mar. 31,
2010
July 1, 2010
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 doesn’t
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.
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 > 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.
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 > 300 people;
– 2006: systems serving 100-299 people;
– 2007: systems serving < 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 < ½ MCL
Every 3 years if > ½ MCL
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.
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.
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 >200’ 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.
NTNC & TNC GWUDI
Requirements
• Once system is notified by mail that they must
evaluate their water source for GWUDI, they
have three options:
1. 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.
2. Collect a total of 2 Microscopic Particulate Analyses
(MPA) during high river stage (February – May) a
minimum of 1 month apart.
3. Assume their source is GWUDI and install approved
treatment.
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
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.
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 (DEQ’s Tanks, ODF private
forestlands, County planning, USFS, BLM,
ODOT,
ODA, SWCD, Watershed councils, etc.)