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.)