Stage 1 and 2Stage 1 and 2Disinfection Byproduct RuleDisinfection Byproduct Rule

presented by:

Joseph Munson

OutlineOutline

• Introduction to Disinfection Introduction to Disinfection ByproductsByproducts

• Stage 1 & 2 OverviewStage 1 & 2 Overview• Initial Distribution System Evaluation Initial Distribution System Evaluation

(IDSE) Options(IDSE) Options• Stage 2 ComplianceStage 2 Compliance• DCTSDCTS• IDSE ToolIDSE Tool

Disinfectants:Disinfectants:• Kill or inactivate Kill or inactivate

disease-causing disease-causing microorganismsmicroorganisms

• React with React with substances substances naturally in naturally in water to form water to form harmful DBPs harmful DBPs

• Produce Produce negative health negative health effects when effects when present in present in excessive levelsexcessive levels

Public Health & Public Health & DisinfectionDisinfection

How Are DBPs Formed?How Are DBPs Formed?

Precursor in Water

NOM

Bromide

+Added

DisinfectantChlorine

Chloramines

Chlorine Dioxide

Ozone

=TTHM

HAA5

Chlorite

Bromate

DBP

Health EffectsHealth Effects

• Disinfectants Disinfectants

(in large doses):(in large doses):−Eye and nose Eye and nose

irritationirritation−Stomach Stomach

discomfortdiscomfort−AnemiaAnemia−Other acute Other acute

short-term health short-term health effects effects

• Byproducts:Byproducts:−Cancer Cancer −Liver problems Liver problems −Kidney problems Kidney problems −Central nervous Central nervous

system problemssystem problems−AnemiaAnemia−Reproductive Reproductive

problems problems

A Delicate BalanceA Delicate Balance

Risk: microbial Risk: microbial contamination contamination vs. DBP vs. DBP formationformation

EPA’s solution: EPA’s solution: control health control health risks from risks from microbials, microbials, disinfectants, disinfectants, and DBPsand DBPs

Result: M-DBP Result: M-DBP Suite of rulesSuite of rules

Microbials

DBP’s

Stage 1 & 2 Stage 1 & 2 DBPR OverviewDBPR Overview

Stage 1 & 2 DBPR Stage 1 & 2 DBPR OverviewOverview

• 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 Population-Based Monitoring and Monitoring and

SchedulingScheduling• Stage 1 DBPRStage 1 DBPR

– Scheduling based on source water type and Scheduling based on source water type and population servedpopulation served

– Monitoring based on source water type, Monitoring based on source water type, population served, population served, and and number of treatment number of treatment plants/wellsplants/wells

• Stage 2 DBPRStage 2 DBPR

– Scheduling based on source water type, Scheduling based on source water type, population served, population served, and population of the largest and population of the largest system in combined distribution system (CDS)system in combined distribution system (CDS)

– Monitoring based on source water type and Monitoring based on source water type and population served (excluding CDS)population served (excluding CDS)

Combined Distribution Combined Distribution Systems (CDSs)Systems (CDSs)

• All systems in a CDS (i.e., wholesalers, All systems in a CDS (i.e., wholesalers, consecutive systems) must comply with consecutive systems) must comply with Stage 2 DBPR requirements on the same Stage 2 DBPR requirements on the same scheduleschedule– Compliance date is based on the population Compliance date is based on the population

of the largest system in the CDS of the largest system in the CDS – Largest system is not necessarily the Largest system is not necessarily the

wholesalerwholesaler• EPA or state has discretion to determine EPA or state has discretion to determine

CDSCDS– Emergency or seasonal connections Emergency or seasonal connections

Consecutive SystemsConsecutive Systems

• Must comply with IDSE Must comply with IDSE requirements requirements

• Must conduct Stage 2 DBPR TTHM Must conduct Stage 2 DBPR TTHM and HAA5 compliance monitoring and HAA5 compliance monitoring

• Must comply with the Stage 1 Must comply with the Stage 1 DBPR requirements for chlorine DBPR requirements for chlorine and chloraminesand chloramines

Compliance Calculation Compliance Calculation & Reporting& 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.

• MRDLs

Stage 1 & 2 DBPR Stage 1 & 2 DBPR MRDL & MCLMRDL & MCL

DisinfectantDisinfectant MRDLMRDL

ChlorineChlorine 4.0 mg/L4.0 mg/L

ChloraminesChloramines 4.0 mg/L4.0 mg/L

Chlorine DioxideChlorine Dioxide 0.8 mg/L0.8 mg/L

Disinfection ByproductDisinfection Byproduct MCLMCL

TTHMTTHM 0.080 mg/L0.080 mg/L

HAA5HAA5 0.060 mg/L0.060 mg/L

BromateBromate 0.010 mg/L0.010 mg/L

ChloriteChlorite 1.0 mg/L1.0 mg/L

• MCLs

Initial DistributionInitial DistributionSystem Evaluation System Evaluation

(IDSE) Options(IDSE) Options

VSS Waiver

40/30 Certificati

on

Standard Monitoring

System Specific Study

IDSE Options

Choose Stage 2 TTHM/HAA5 Sites for Compliance

Conduct Stage 2 Compliance Monitoring

LRAA

1 3 42

Existing Data Only New and Existing Data

Sch.Sch. Systems Systems Serving: Serving:

Submit 40/30 Submit 40/30 Certification, Certification, SM, SSS Plan, SM, SSS Plan,

or receive or receive VSS Waiver VSS Waiver

by:by:

Complete SM Complete SM or SSS By:or SSS By:

Submit IDSE Submit IDSE Report (only Report (only

systems systems conducting SM conducting SM

or SSS) by:or SSS) by:

11 >> 100,000 100,000 Oct. 1, 2006Oct. 1, 2006 Sept. 30, Sept. 30, 20082008 Jan. 1, 2009Jan. 1, 2009

22 50,000–50,000–99,99999,999 Apr. 1, 2007Apr. 1, 2007 Mar. 31, Mar. 31,

20092009 July 1, 2009July 1, 2009

33 10,000–10,000–49,99949,999 Oct. 1, 2007Oct. 1, 2007 Sept. 30, Sept. 30,

20092009 Jan. 1, 2010Jan. 1, 2010

44 < 10,000< 10,000 Apr. 1, 2008Apr. 1, 2008 Mar. 31, Mar. 31, 20102010 July 1, 2010July 1, 2010

Schedule for systems in a combined distribution system is based on that of the largest system in the combined

distribution system

IDSE IDSE Implementation TimelineImplementation Timeline

Very Small System Very Small System (VSS) Waivers IDSE (VSS) Waivers IDSE

OptionsOptions

Eligibility CriteriaEligibility Criteria

• Systems must Systems must – Serve fewer than 500 peopleServe fewer than 500 people– Have taken TTHM and HAA5 samplesHave taken TTHM and HAA5 samples

Reduced monitoring acceptableReduced monitoring acceptable Operational data acceptableOperational data acceptable

• 137 systems out of an eligible 243 137 systems out of an eligible 243 systems in South Dakota have received systems in South Dakota have received their VSS Waivertheir VSS Waiver

Note: EPA or the state may deny a VSS Waiver for any reason, even if system meets

all eligibility criteria

VSS WaiversVSS Waivers

• Waivers effective immediatelyWaivers effective immediately− No application necessaryNo application necessary− Systems must meet all criteriaSystems must meet all criteria

• EPA or the state can require Standard Monitoring or EPA or the state can require Standard Monitoring or System Specific StudySystem Specific Study

• VSS Waiver is only a waiver from additional IDSE VSS Waiver is only a waiver from additional IDSE activitiesactivities− No Standard Monitoring or System Specific Study No Standard Monitoring or System Specific Study

PlanPlan− No IDSE Report No IDSE Report

• Continue compliance with Stage 1 DBPR until Stage 2 Continue compliance with Stage 1 DBPR until Stage 2 DBPR compliance begins DBPR compliance begins – Complete a monitoring plan for the Stage 2 DBPRComplete a monitoring plan for the Stage 2 DBPR

40/30 Certification40/30 Certification

Eligibility CriteriaEligibility 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 DataOperational Data

• EPA or the state may allow systems to use EPA or the state may allow systems to use operational data to qualify for certificationoperational data to qualify for certification– Should be equivalent to Stage 1 DBPR dataShould be equivalent to Stage 1 DBPR data

• ConsiderationsConsiderations– Samples taken and analyzed by approved Samples taken and analyzed by approved

methods at a certified labmethods at a certified lab– Adequate number of sample sites for system Adequate number of sample sites for system

sizesize– Samples taken at appropriate locations Samples taken at appropriate locations

(average to maximum residence time)(average to maximum residence time)– Samples taken at appropriate frequency and Samples taken at appropriate frequency and

during month of warmest water temperatureduring month of warmest water temperature

Submitting a 40/30 LetterSubmitting a 40/30 Letter

• Once a system has collected a sufficient Once a system has collected a sufficient amount of data it can prepare a 40/30 amount of data it can prepare a 40/30 Certification Letter and submit it to the EPA:Certification Letter and submit it to the EPA: – Electronically (through IDSE tool)Electronically (through IDSE tool)

– Hard-copy (through mail)Hard-copy (through mail) US EPA-IPMC US EPA-IPMC PO Box 98 PO Box 98

Dayton, OH 45401-0098Dayton, OH 45401-0098

System InformationSystem InformationPWS Name_____________________ PWS ID:_______________________PWS Name_____________________ PWS ID:_______________________Street Address:__________________ City, State, Zip:_________________Street Address:__________________ City, State, Zip:_________________Population Served:_______________ Source Water Type:Population Served:_______________ Source Water Type: Ground Ground

Subpart HSubpart HSystem Type: System Type: CWS CWS NTNCWS NTNCWSCombined Distribution System: Combined Distribution System: Wholesale Wholesale Consecutive Consecutive Neither Neither Contact PersonContact PersonName:Name: _______________________Title: ___________________________________________Title: ____________________Phone Number:__________________Fax Number (if available):____________Phone Number:__________________Fax Number (if available):____________Email Address (if available):_______________________Email Address (if available):_______________________CertificationCertificationI hereby certify that each individual Stage 1 DBPR compliance sample I hereby certify that each individual Stage 1 DBPR compliance sample

collected from ________ to _______ was less than or equal to 0.040 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 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 eligible, each individual sample must be equal to or below these values. I also certify that this PWS collected all required Stage 1 values. I also certify that this PWS collected all required Stage 1 samples and did not have any monitoring violations during this time samples and did not have any monitoring violations during this time period. period.

Signature:_________________ Date:______________________Signature:_________________ Date:______________________

Example 40/30 Certification Example 40/30 Certification LetterLetter

Standard MonitoringStandard Monitoring

Standard Monitoring IDSE Standard Monitoring IDSE StepsSteps

Select Standard Monitoring Locations

Prepare and Submit Standard Monitoring Plan

Conduct Standard Monitoring

Select Stage 2 DBPR compliance monitoring locations

Prepare and Submit IDSE report

1

2

3

4

5

EPA or the state approves the Standard Monitoring Plan

IDSE Schedule for IDSE Schedule for Standard MonitoringStandard Monitoring

SchSch..

Systems Systems ServingServing

Submit Submit PlanPlan

Complete Complete MonitoringMonitoring

Submit Submit IDSE IDSE

ReportReport

11 >> 100,000 100,000 10/1/200610/1/2006 9/30/20089/30/2008 1/1/2001/1/20099

2250,000 –50,000 –99,99999,999 4/1/20074/1/2007 3/31/20093/31/2009 7/1/2007/1/200

99

3310,000 –10,000 –49,99949,999 10/1/200710/1/2007 9/30/20099/30/2009 1/1/2011/1/201

00

44 < 10,000< 10,000 4/1/20084/1/2008 3/31/20103/31/2010 7/1/2017/1/20100Schedule for systems in a combined distribution system is

based on that of largest system in the combined distribution system

Required Components of Required Components of Standard Monitoring PlanStandard 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 Standard Monitoring RequirementsRequirements

• 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 TTHM and HAA5 Standard MonitoringStandard Monitoring(1)(1)

• For groundwater systems or systems that purchase groundwaterFor groundwater systems or systems that purchase groundwater

PopulationFrequen

cy(in year)

Total

Sites

Near EP

ARTHigh TTHM

High HAA5

< 500 < 500 consecutiveconsecutive

1 (during 1 (during peak peak

historical historical month)month)(2)(2)

22 11 -- 11 --

< 500 non-< 500 non-consecutiveconsecutive 22 -- -- 11 11

500-9,999500-9,9994 (every 4 (every 90 days)90 days)

22 -- -- 11 11

10,000 – 99,99910,000 – 99,999 66 11 11 22 22

100,000-499,999100,000-499,999 88 11 11 33 33(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 TTHM and HAA5 Standard MonitoringStandard Monitoring(1)(1)

• For Subpart H systems and systems that purchase For Subpart H systems and systems that purchase Subpart H waterSubpart H water

PopulationPopulation FrequencyFrequency TotalTotal Near Near EPEP ARTART High High

TTHMTTHMHigh High HAA5HAA5

<500 consecutive<500 consecutive 1 (during 1 (during peak peak

historical historical month)month)(2)(2)

22 11 -- 11 --

<500 non-<500 non-consecutiveconsecutive 22 -- -- 11 11

500-3,300 500-3,300 consecutiveconsecutive

4 (every 90 4 (every 90 days)days)

22 11 -- 11 --

500-3,300 500-3,300

non-consecutivenon-consecutive22 -- -- 11 11

3,301-9,9993,301-9,999 44 -- 11 22 11

10,000-49,99910,000-49,999 6 (every 60 6 (every 60 days)days)

88 11 22 33 22

50,000- 249,99950,000- 249,999 1616 33 44 55 44

Standard Monitoring Standard Monitoring Site Selection – Site Selection –

JustificationJustification• Plan must include a justification Plan must include a justification

for the selection of sites to be for the selection of sites to be sampled during Standard sampled during Standard MonitoringMonitoring

• Data sources and toolsData sources and tools– Distribution system mapsDistribution system maps– Water quality dataWater quality data– Distribution system operating dataDistribution system operating data

Final “Selected” SitesFinal “Selected” Sites

• Some site selection will be obviousSome site selection will be obvious– Near entry pointNear entry point

• Others will require professional judgmentOthers will require professional judgment– Consider geographic representationConsider geographic representation– Consider hydraulic representationConsider hydraulic representation– Consider areas fed by sources with higher Consider areas fed by sources with higher

DBP precursorsDBP precursors– Use sites that “multi-task”Use sites that “multi-task”– Consider accessibilityConsider accessibility

Submitting Submitting Standard Monitoring PlanStandard Monitoring Plan

• Once the system has collected Once the system has collected and analyzed its information, it and analyzed its information, it must prepare the plan and submit must prepare the plan and submit it to EPA or the stateit to EPA or the state– Electronically (through IDSE tool)Electronically (through IDSE tool)– Hard-copy (mail to IPMC address) Hard-copy (mail to IPMC address)

• Must include required informationMust include required information

System Specific Study System Specific Study (SSS)(SSS)

Stage 2 Compliance Stage 2 Compliance Monitoring Schedule Monitoring Schedule

Sch.Sch.SystemSystem

Serving:Serving:Start Stage 2 Compliance Start Stage 2 Compliance

Monitoring By:Monitoring By:

11 >> 100,000 100,000 April 1, 2010April 1, 2010

22 50,000 –99,99950,000 –99,999 Oct. 1, 2012Oct. 1, 2012

33 10,000 –49,99910,000 –49,999 Oct. 1, 2013Oct. 1, 2013

44 < 10,000< 10,000Oct 1, 2013Oct 1, 2013

Oct 1, 2014*Oct 1, 2014*

* Date for systems that were required to conduct Crypto monitoring under LT2

Questions?Questions?

Information Processing Information Processing &&

ManagementManagement Center Center (IPMC) and Data (IPMC) and Data

Collection & Tracking Collection & Tracking System (DCTS)System (DCTS)

Information Processing Information Processing andandManagement Center Management Center (IPMC)(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 What can be submitted to the IPMC?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 IPMC Contact InformationInformation

• The IPMC will receive, sort, scan, & perform data entry for Stage 2 DBPR and LT2ESWTR submissions into the DCTS.Mailing Address:Stage 2 DBPR &LT2ESWTR IPMCP O Box 98Dayton, OH 45401

Fax Number:937-586-

6557E-mail Address:

stage2mdbp@epa.gov

Data Collection & Data Collection & Tracking System (Tracking System (DCTSDCTS))

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 ToolAccessing 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 ToolAccessing 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 DCTSAccessing 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 Access Request Process for Individuals With a CRK KeyIndividuals 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 User Approval within DCTSDCTS

• 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 AccessCRK AccessGo to: http://cdx.epa.gov/preregistration

What if I Did Not What if I Did Not Receive a CRK Letter Receive a CRK Letter

and Need toand Need toRegister?Register?

Access Request Access Request ProcessProcess

We recommend that you use the Registration Guide (sent with email handout)

Go to https://cdx.epa.gov

Access Request Access Request ProcessProcess

Steps for New DCTS Users with No CRK andNo 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:Add Program:Step C for All Users

Access Request ProcessAccess Request ProcessSteps 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 DCTS Quick Guide to Logging In for PWSsto Logging In for PWSs

• For more detailed information, refer to the DCTS Quick Guide

• http://www.epa.gov/ogwdw/disinfection/tools/pdfs/instructions_mdbp_dcts.pdf

• Please send questions to: stage2mdbp@epa.gov

Questions?Questions?

IDSE Tool WizardIDSE Tool WizardOverviewOverview

IDSE Tool: PurposeIDSE 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: InformationIDSE Tool: Information

• The IDSE Tool is comprised of two modules

– The Wizard– Plan/Report Entry

General Information - General Information - WizardWizard

• 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 VersionIDSE 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 DemonstrationDemonstration

IDSE Tool – CD VersionIDSE Tool – CD Version

• To obtain the CD Version– Visit the Stage 2 DBPR Web site: http://

www.epa.gov/safewater/disinfection/tools/tools-idse.html

– Contact the EPA Warehouse: (202)260-3103

– E-mail stage2mdbp@epa.gov

Questions?Questions?