Ohio EPA UpdateHolly Kaloz

Manager, Compliance Assurance SectionDivision of Drinking and Ground Waters

April 24, 2014

Ohio Section AWWA SE District Spring Meeting

• Revised Total Coliform Rule (RTCR)• Save a Dime, Sample on Time!• Lab Oversight Updates• Lead Free Updates• Legionella Treatment• Electronic Reporting• Backflow Rules Updates• Operator Certification• Harmful Algal Blooms (HABs)• Water Supply Revolving Loan Account (WSRLA)

Overview

USEPA Rule issued as Final

Ohio rules adopted

Ohio rules out for public comment

Ohio rules effective

RTCR Background

• Applies to ALL public water systems (PWS)• MCL for total coliform eliminated• New MCL for E. coli• Treatment Technique (Find and Fix Approach)

• Level 1 or Level 2 Assessments

RTCR Big Picture

• Large Community PWS Routine monitoring is unchanged

• Small Community PWS (pop <1001) One sample per month Ohio EPA does not plan to adopt Fed provision for quarterly sampling

RTCR Basics - Routine Monitoring

Small Noncommunity PWS (pop <1001)•Affected most by new rule•Baseline will remain 1 sample per quarter•Ohio EPA does not plan to adopt reduced annual monitoring•In the month following TC+: 3 instead of 5•Triggered monthly monitoring

2 or more TC monitoring violations w/in past 12 months Combination of one Level 1 Assess. and one TC mon. viol. Level 2 Assessment Treatment technique violation

RTCR Basics - Routine Monitoring

• Seasonal Systems – By definition a PWS that serves water a portion of

the year and shuts-down

• Start-up procedure and report • TC sample 1x/month during season will be

proposed as baseline

RTCR Basics - Routine Monitoring

• 3 instead of 4 • Additional sets of repeats• E. coli is sole fecal indicator• Failure to take all is not a monitoring violation

Triggers a Level 1 Assessment

• Consecutive GW Systems must notify supplier

RTCR Basics - Repeat Monitoring

• Triggers > 5.0% TC+ for PWS taking 40 or more samples/mo 2 or more TC+ for PWS taking <40 samples/mo Failure to take all repeat samples

• Goal – ID problems w/ sampling and cause of TC+• Requirements

By PWS – Ohio intends to assist by phone Required elements – emphasis on sampling protocol and

distribution system upsets 30 day turnaround Failure to complete is TT violation

RTCR Basics - Level 1 Assessments

9

• Triggers An E. coli MCL, or A second L1 Assess within 12 months

• Goal – ID sanitary defects and cause of EC+• Requirements

By a state approved person – Ohio EPA expects to do them Required elements – same as L1 but more detailed 30 day turnaround Failure to complete is TT violation

RTCR Basics - Level 2 Assessments

10

• E. coli MCL violation – Tier 1 PN

• Treatment technique violations – Tier 2 PN• Monitoring violations• Reporting violations

RTCR Basics - Violations

ROUTINE REPEATEC+ TC+EC+ Any missing sampleTC+ EC+TC+ TC+ - but no E. coli

analysis

• Monitoring violations - only 2 Failure to take routine total coliform sample Failure to analyze for E. coli following a TC+

routine sample

• Reporting violations - new ones Failing to submit an Assessment form on time Failure by a seasonal PWS to submit

documentation that required start-up procedure was completed

RTCR Basics - Violations

Save a Dime, Sample on Time!

• New Ohio EPA program to provide a deterrent to violations and increase public health protection.

• More expensive to fail to sample than it is to sample.• Beginning January 1, 2014, there will be a penalty of

$150 or more for each monitoring violations. (NOVs after 1st qtr)

• Don’t put your consumers at risk, sample on time!

Lab Oversight Update

• Assessing reporting compliance for laboratories• Began issuing routine Notices of Violation to

laboratories for reporting violations in 3rd quarter 2013– Significant decrease in the number of late sample reports

• May result in further enforcement

Lead Free Requirement

• U.S. EPA has posted a revised list of FAQs at: http://water.epa.gov/drink/info/lead/upload/epa815s13001.pdf

• Repairs have been clarified• Hydrants exempted from coverage• Still some problematic language• Pb/Cu Long Term Revisions

– NDWAC advising USEPA

Legionella Treatment

• Increasing outbreaks• Hospitals seeking additional treatment• Makes them a regulated PWS• Treatments

– Copper Silver Ionization– Chlorine Dioxide

• Operational/Distribution Requirements• Statewide group working on guidance for

healthcare facilities

Electronic Reporting

Requirement to submit monthly operational report (MOR) to Ohio EPA using eDWR by the following dates:

Population Served Latest Date to Begin

3,301 or more July 1, 2012

501 - 3,300 July 1, 2013

500 or fewer July 1, 2014

Contact Brian Tarver with questions (614) 644-2752

Backflow Rules

• Working on addressing Commerce’s recent comments

• Sub-group formed for unresolved items– Ohio EPA– PWS – ORWA and OAWWA– Commerce

• Manual is being revised to address comments• Reopen booster pump rule to address conflicts

• Rule Making – Coming Soon• Class 1 ORC provision• Allow individual that passes Class I water supply exam but does not

meet experience requirements to be the ORC if specific conditions are met

• Clarify classification of systems• satellite/consecutive systems• TNC < 250 with 4-log disinfection or nitrate removal treatment

Operator Certification

• Class I Water Supply Training • Fill in forms• Opcert list serve• Eapps is coming eventually• Approved exam provider in place

Operator Certification

Approved Exam Provider

• Association of Boards of Certification (ABC)– 5 locations– 3 hour test– 100 questions

Two Pathways for Certification using ABC Testing

Ohio EPA Testing Service– Application (attestation)– Immediate registration– EPA equivalent exam– 30 day retake waiting period– Full fees required for a retake

Certification using ABC Testing

Approved Exam Provider Fees

• Ohio EPA Testing Service– Exam Fee $47– Exam administration fee $64– Total $111

How does an operator get Ohio EPA certified via ABC Exam?

1. Pass ABC Exam2. Apply to Ohio EPA

– $45 Fee– Document experience (OITs should wait to apply until

they meet experience requirements)3. Ohio EPA Issues CertificateOR - Paper and pencil tests will still be offered 2 times per

year at the Ohio Expo Center

Eapplication and Epayment

• E-application–Ebiz center

• Exam applications• Renewal applications• Contact hour applications

• Epayment

Operational Records

OAC 3745-7-09– “Accurate and Authentic”– Maintained onsite available for 24 hour inspection– At a minimum, the following information shall be

recorded:(a) Identification of the public water system, sewerage system, or treatment works;(b) Date and times of arrival and departure for the operator of record and any other operator required by this chapter;

Operational Records(c) Specific operation and maintenance activities that affect or have the potential to affect the quality or quantity of sewage or water conveyed, effluent or water produced;(d) Results of tests performed and samples taken, unless documented on a laboratory sheet; (e) Performance of preventative maintenance and repairs or requests for repair of the equipment that affect or have the potential to affect the quality or quantity of sewage or water conveyed, effluent or water produced; and(f) Identification of the persons making entries.

Harmful Algal Blooms (HABs)• HAB Monitoring Summary

– Ohio EPA collected 1268 raw and finished water cyanotoxin samples at 40 water systems

– PWS have submitted results for over 600 raw and finished water cyanotoxin samples (7 systems)

– Cyanotoxins have been detected in the majority of the source waters sampled in Ohio

– Three finished water microcystin detections (>0.25ug/L), one above drinking water threshold (1.0 ug/L)

– First drinking water advisory issued in 2013

Ohio Harmful Algal Blooms (HABs) 2010 - 2013

Recreation Use Advisories

Water Systems with HABs in Source Water

Welston- Lake Alma 2010

Lima 2011

Findlay 2012

Bur Oak 2010

Clermont CO- Harsha Lake 2012

Examples of Harmful Algal Bloom on Ohio’s Inland Public

Water Supply Lakes and Reservoirs

Wilmington -Caesar Creek Lake 2011Bowling Green 2013

Akron- Lake Rockwell 2011

Example of Source Water With High Toxin Concentration (>100 ug/L microcystin)

Harmful Algal Blooms (HABs)

• Preparing for 2014 HAB Season– Meetings with USEPA, NOAA, CDC and others to

share information– Prioritize funding for HAB-related treatment

• Added points to WSLRA ranking system

– Algae Questionnaire coming soon• Webinars scheduled for April 29 and 30

– Updating HAB Strategy

• $193.3M requested loans for upcoming project year– 79 water systems for 119 projects– Range from $5,000 to $24M per project, average

$1M per project– All projects should get funded

• Considering offering targeted funding for emergency power in future

Water Supply Revolving Loan Account (WSRLA)

Questions?

Holly KalozOhio EPA, DDAGW50 W. Town St., Suite 700Columbus, Ohio 43215614-644-2752holly.kaloz@epa.ohio.gov