The Stage 2 Disinfection By-Products The Stage 2 Disinfection By-Products Rule Rule

DoD/EPA State Conference DoD/EPA State Conference Compliance TrackCompliance Track

Atlanta, GAAtlanta, GA June 21, 2007June 21, 2007

Amy NewboldAmy NewboldEnvironmental EngineerEnvironmental EngineerDrinking Water SectionDrinking Water Section

EPA Region 4EPA Region 4

Review: What are Disinfection By-Review: What are Disinfection By-Products?Products?

Precursor in Water

Natural Organic Matter (NOM)

Bromide+

Added Disinfectant

Chlorine

Chloramines

Chlorine Dioxide

Ozone

= Total Trihalomethanes (TTHM)

Haloacetic Acids (HAA5)

Chlorite

Bromate

DBP

Health Risks of DBPs – Health Risks of DBPs – Public NotificationPublic Notification

DBPs, including trihalomethanes (THMs) and haloacetic acids (HAAs), have been shown to cause cancer in laboratory animals.

DBPs have been shown to affect the liver and the nervous system, and cause reproductive or developmental effects in laboratory animals.

Exposure to certain DBPs may produce similar effects in people. EPA has set standards to limit exposure to THMs, HAAs, and other DBPs

Stage 1 Disinfection Stage 1 Disinfection By-Products RuleBy-Products Rule

Published December 1998Published December 1998

Applies to all CWS and NTNCWS that treat their water with a chemical Applies to all CWS and NTNCWS that treat their water with a chemical disinfectant for either primary or residual treatmentdisinfectant for either primary or residual treatment

TTHM MCL = 0.080 mg/LTTHM MCL = 0.080 mg/L

HAA5 MCL = 0.060 mg/LHAA5 MCL = 0.060 mg/L

Monitoring depends on number of “plants”Monitoring depends on number of “plants” Multiple wells drawing from same aquifer may be considered one treatment plantMultiple wells drawing from same aquifer may be considered one treatment plant

Sample at Max Residence Time (MRT) Sample at Max Residence Time (MRT) and Average Residence Time (ART) if taking more than 1 sample per plantand Average Residence Time (ART) if taking more than 1 sample per plant

Compliance based on Running Annual Average of quarterly resultsCompliance based on Running Annual Average of quarterly results

Stage 2 Disinfection Stage 2 Disinfection By-Products Rule - NEWBy-Products Rule - NEW

Published January 4, 2006Published January 4, 2006

Applies to CWS & NTNCWS that add and/or deliver water that is treated with a Applies to CWS & NTNCWS that add and/or deliver water that is treated with a primary or residual disinfectant other than UV. primary or residual disinfectant other than UV.

Consecutives Systems Required to Monitor under Stage 2.Consecutives Systems Required to Monitor under Stage 2.

MCLs are the sameMCLs are the same

Compliance based on Locational Running Annual Average instead of Running Compliance based on Locational Running Annual Average instead of Running Annual Average.Annual Average.

Monitoring based on population served instead of number of plantsMonitoring based on population served instead of number of plants

Has 2 PartsHas 2 Parts1.1. 2006-20102006-2010 - - Initial Distribution System Evaluation (IDSE)Initial Distribution System Evaluation (IDSE)2.2. 2012 and beyond -2012 and beyond - Compliance MonitoringCompliance Monitoring

Operational Evaluation Levels (2012 and beyond)Operational Evaluation Levels (2012 and beyond)

New DefinitionsNew Definitions

Wholesale SystemWholesale System - is a public water system (PWS) that treats - is a public water system (PWS) that treats source water as necessary to produce finished water and then source water as necessary to produce finished water and then delivers some or all of that finished water to another PWS. Delivery delivers some or all of that finished water to another PWS. Delivery may be through a direct connection or through the distribution may be through a direct connection or through the distribution system of one or more consecutive systems.system of one or more consecutive systems.

Consecutive SystemConsecutive System - is a PWS that receives some or all of its - is a PWS that receives some or all of its finished water from one or more wholesale systems. Delivery may finished water from one or more wholesale systems. Delivery may be through a direct connection or through the distribution system of be through a direct connection or through the distribution system of one or more consecutive systems.one or more consecutive systems.

Combined Distribution System (CDS)Combined Distribution System (CDS) - is the interconnected - is the interconnected distribution system consisting of the distribution systems of distribution system consisting of the distribution systems of wholesale systems and of the consecutive systems that receive wholesale systems and of the consecutive systems that receive finished water.finished water.

More New Definitions...More New Definitions...

Dual Sample SetDual Sample Set - is a set of two samples collected at the same - is a set of two samples collected at the same time and same location, with one sample analyzed for TTHM and time and same location, with one sample analyzed for TTHM and the other sample analyzed for HAA5. Dual sample sets are collected the other sample analyzed for HAA5. Dual sample sets are collected for the purposes of conducting an IDSE (part1) for the purposes of conducting an IDSE (part1) andand determining determining compliance with the TTHM and HAA5 MCLs (part 2).compliance with the TTHM and HAA5 MCLs (part 2).

Locational Running Annual AverageLocational Running Annual Average - is the average of sample - is the average of sample analytical results for samples taken at a particular monitoring analytical results for samples taken at a particular monitoring location during the previous 4 calendar quarters. location during the previous 4 calendar quarters.

RAA vs. LRAA CalculationRAA vs. LRAA Calculation

Stage 1 – RAA (4 samples per plant example)Stage 1 – RAA (4 samples per plant example) (Samp1 + Samp2 + Samp3 + Samp4)/4 = Quarterly Average(Samp1 + Samp2 + Samp3 + Samp4)/4 = Quarterly Average (Q1 + Q2 + Q3 + Q4)/4 = RAA(Q1 + Q2 + Q3 + Q4)/4 = RAA

Stage 2 – IDSE and Compliance MonitoringStage 2 – IDSE and Compliance Monitoring (Site1 Q1 + Site1 Q2 + Site1 Q3 + Site1 Q4)/4 = LRAA for Site 1(Site1 Q1 + Site1 Q2 + Site1 Q3 + Site1 Q4)/4 = LRAA for Site 1 (Site2 Q1 + Site2 Q2 + Site2 Q3 + Site2 Q4)/4 = LRAA for Site 2(Site2 Q1 + Site2 Q2 + Site2 Q3 + Site2 Q4)/4 = LRAA for Site 2 (Site3 Q1 + Site3 Q2 + Site3 Q3 + Site3 Q4)/4 = LRAA for Site 3(Site3 Q1 + Site3 Q2 + Site3 Q3 + Site3 Q4)/4 = LRAA for Site 3 (Site4 Q1 + Site4 Q2 + Site4 Q3 + Site4 Q4)/4 = LRAA for Site 4(Site4 Q1 + Site4 Q2 + Site4 Q3 + Site4 Q4)/4 = LRAA for Site 4

Part 1 of the Stage 2 Rule - Part 1 of the Stage 2 Rule -

The Initial Distribution System The Initial Distribution System Evaluation (IDSE)Evaluation (IDSE)

2006 - 20102006 - 2010

Initial Distribution System Initial Distribution System EvaluationEvaluation

Applies to NTNCWS that serve > 10,000 and all CWSApplies to NTNCWS that serve > 10,000 and all CWS

Purpose is to Identify best locations to monitor TTHMs Purpose is to Identify best locations to monitor TTHMs and HAA5s. and HAA5s.

One-time Study – 1 year of increased monitoringOne-time Study – 1 year of increased monitoring

Use results from IDSE and Stage 1 data (part 1), to Use results from IDSE and Stage 1 data (part 1), to select compliance monitoring locations for the Stage 2 select compliance monitoring locations for the Stage 2 DBPR (part 2). DBPR (part 2).

Stage 2 DBPR – IDSE OptionsStage 2 DBPR – IDSE Options

VSS Waiver

40/30 Certification

System Specific Study

Standard Monitoring

(Most Common Option)

IDSE Options

1 3 42

VSS WaiversVSS Waivers

Criteria Criteria Serve fewer than 500 peopleServe fewer than 500 people Have taken TTHM and HAA5 samplesHave taken TTHM and HAA5 samples

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

Primacy agency may deny waiver and require Standard Monitoring or Primacy agency may deny waiver and require Standard Monitoring or System Specific StudySystem Specific Study

VSS Waiver is only a waiver from additional IDSE activities. VSS Waiver is only a waiver from additional IDSE activities.

No IDSE Report No IDSE Report

Continue compliance with Stage 1 DBPR until Stage 2 DBPR Continue compliance with Stage 1 DBPR until Stage 2 DBPR compliance begins & Revise Stage 1 DBPR monitoring plan for Stage 2 compliance begins & Revise Stage 1 DBPR monitoring plan for Stage 2 DBPRDBPR

40/30 Eligibility Criteria40/30 Eligibility Criteria

Systems must have taken all required Stage 1 DBPR samples:Systems must have taken all required Stage 1 DBPR samples: Within specified 2-year eligibility period based on system sizeWithin specified 2-year eligibility period based on system size No individual sample can have exceeded:No individual sample can have exceeded:

• 0.040 mg/L for TTHM (40 0.040 mg/L for TTHM (40 μμg/L)g/L)• 0.030 mg/L for HAA5 (30 0.030 mg/L for HAA5 (30 μμg/L)g/L)

No TTHM or HAA5 monitoring violations within specified time periodNo TTHM or HAA5 monitoring violations within specified time period Continue compliance with Stage 1 DBPR until Stage 2 DBPR compliance Continue compliance with Stage 1 DBPR until Stage 2 DBPR compliance

begins & Revise Stage 1 DBPR monitoring plan for Stage 2 DBPRbegins & Revise Stage 1 DBPR monitoring plan for Stage 2 DBPR

Sch.Sch. PopulationPopulation Eligibility Period Beginning No Eligibility Period Beginning No Earlier Than*:Earlier Than*:

Submit 40/30 Submit 40/30 Certification By:Certification By:

11 >>100,000100,000

January 2004January 2004

Oct. 1, 2006Oct. 1, 2006

22 50,000-99,99950,000-99,999 Apr. 1, 2007Apr. 1, 2007

33 10,000-49,99910,000-49,999January 2005January 2005

Oct. 1, 2007Oct. 1, 2007

44 <10,000<10,000 Apr. 1, 2008Apr. 1, 2008

System Specific Studies (HQ)System Specific Studies (HQ)

2 Types of SSS:2 Types of SSS:

Hydraulic Model Hydraulic Model • Specific requirements laid out in IDSE Guidance Manual – Chapter 6Specific requirements laid out in IDSE Guidance Manual – Chapter 6• Submit SSS planSubmit SSS plan• HQ will review all hydraulic models in Region 4HQ will review all hydraulic models in Region 4• If approved, conduct monitoring based on System Specific Study Plan If approved, conduct monitoring based on System Specific Study Plan

Existing Monitoring ResultsExisting Monitoring Results • Samples must be collected no earlier than 5 years prior to the study plan Samples must be collected no earlier than 5 years prior to the study plan

submission date.submission date.• Submit SSS planSubmit SSS plan• HQ will review most existing monitoring SSS unless State requested HQ will review most existing monitoring SSS unless State requested

otherwiseotherwise• If Approved, continue to monitor according to Stage 1 until Stage 2 If Approved, continue to monitor according to Stage 1 until Stage 2

Compliance period begins.Compliance period begins.

Most Common IDSE Submission – Most Common IDSE Submission – Standard Monitoring PlanStandard Monitoring Plan

Standard Monitoring:Standard Monitoring: One year of increased distribution One year of increased distribution system monitoring to find locations with high TTHMs an system monitoring to find locations with high TTHMs an HAA5s.HAA5s.

Stage 1 Monitoring Will Continue During IDSEStage 1 Monitoring Will Continue During IDSE Results from IDSE Standard Monitoring should not be used to Results from IDSE Standard Monitoring should not be used to

determine compliance with Stage 1 determine compliance with Stage 1 MUST continue to monitor Stage 1 sites according to Stage 1 MUST continue to monitor Stage 1 sites according to Stage 1

monitoring plan.monitoring plan.

Standard Monitoring IDSE StepsStandard Monitoring IDSE Steps

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

4

5

EPA or the state approves the Standard Monitoring Plan

3 If you haven’t heard from EPA

or State within 12 months of

submitting SMP

How to Prepare a Standard Monitoring How to Prepare a Standard Monitoring Plan (SMP)Plan (SMP)

Use Form 6 of the IDSE Guidance Manual (Chapter 7) http://www.epa.gov/safewater/disinfection/stage2http://www.epa.gov/safewater/disinfection/stage2

Submit by mail or email to EPASubmit by mail or email to EPA• Email to: stage2mdbp@epa.govEmail to: stage2mdbp@epa.gov• Mail to: Stage 2 DBPR Mail to: Stage 2 DBPR

US EPA – IPMCUS EPA – IPMC PO Box 98PO Box 98 Dayton, OH 45401-0098Dayton, OH 45401-0098

Or Use the IDSE Tool on website:Or Use the IDSE Tool on website: http://www.epa.gov/safewater/disinfection/tools/tools-idse.htmlhttp://www.epa.gov/safewater/disinfection/tools/tools-idse.html

Submit Distribution Schematic Showing:Submit Distribution Schematic Showing: Locations of SourcesLocations of Sources Entry PointsEntry Points Storage FacilitiesStorage Facilities Standard Monitoring LocationsStandard Monitoring Locations Stage 1 Monitoring LocationsStage 1 Monitoring Locations

Standard Monitoring Requirements Standard Monitoring Requirements Ground WaterGround Water

Monitoring Requirements Based PWS population (dual sample sets)Monitoring Requirements Based PWS population (dual sample sets)

For For Groundwater systemsGroundwater systems or systems that purchase GW or systems that purchase GW

Population Frequency Total Near EP ART High TTHM High HAA5

< 500 1/year(2) 2 1(3) - 1 -

500-9,999

4 (every 90 days)

2 - - 1 1

10,000 – 99,999 6 1 1 2 2

100,000-499,999 8 1 1 3 3

> 500,000 12 2 2 4 4

Standard Monitoring Requirements – Standard Monitoring Requirements – Surface WaterSurface Water

(CFR 141.601)(CFR 141.601)

Population Frequency Total Near EP ART High TTHM

High HAA5

<500 1/year (2) 2 1(3) - 1 -

500-3,3004 (every 90

days)

2 - - 1 1

3,301-9,999 4 - 1 2 1

10,000-49,999

6 (every 60 days)

8 1 2 3 2

50,000- 249,999 16 3 4 5 4

250,000-999,999 24 4 6 8 6

1,000,000-4,999,999 32 6 8 10 8

> 5,000,000 40 8 10 12 10

For Surface and GWUDI systems and systems that purchase

surface or GWUDI

Good Site Selection Characteristics (Use Good Site Selection Characteristics (Use Chapter 7 of Guidance Manual):Chapter 7 of Guidance Manual):

Entry PointsEntry Points Disinfected Entry Points (excluding pure UV)Disinfected Entry Points (excluding pure UV)

Average Residence Time SitesAverage Residence Time Sites Flow weighted or population weightedFlow weighted or population weighted Tracer StudyTracer Study Disinfectant Residual AvgDisinfectant Residual Avg

High TTHM SitesHigh TTHM Sites High Water TempHigh Water Temp Increased Water AgeIncreased Water Age Near Dead Ends (before last group of customers)Near Dead Ends (before last group of customers) Hydraulically downstream of storage tanksHydraulically downstream of storage tanks

High HAA5 SitesHigh HAA5 Sites High Water TempHigh Water Temp Low ResidualsLow Residuals Lower Water Age (if biodegradation is occurring)Lower Water Age (if biodegradation is occurring) Increased Water Age (if no biodegradation)Increased Water Age (if no biodegradation)

Biodegradation CheckBiodegradation Check

Three Questions:Three Questions: Are the highest HAA5 values typically in the summer months?Are the highest HAA5 values typically in the summer months? Are the highest HAA5 values at MRT?Are the highest HAA5 values at MRT? Do highest HAA5 values generally occur at same time of year Do highest HAA5 values generally occur at same time of year

as TTHMs?as TTHMs?

If Yes to all 3 – unlikely that biodegradation is taking If Yes to all 3 – unlikely that biodegradation is taking placeplace

If No to Any – HAA compounds may be degrading If No to Any – HAA compounds may be degrading due to biological activity.due to biological activity.

What’s Your Schedule?What’s Your Schedule?

Schedule

Sys Serving (or

connected to a sys

serving):

Submit 40/30, SMP, or SSS By:

Complete Standard

Monitoring or SSS By:

Submit IDSE Report By:

1 > 100,000 10/1/2006 9/30/2008 1/1/2009

2 50,000–99,999 4/1/2007 3/31/2009 7/1/2009

3 10,000–49,999 10/1/2007 9/30/2009 1/1/2010

4 < 10,000 4/1/2008 3/31/2010 7/1/2010

IDSE Schedule determined by the population served a PWS or by the largest IDSE Schedule determined by the population served a PWS or by the largest

population served by a PWS in your CDS.population served by a PWS in your CDS.

Review of Standard Monitoring PlanReview of Standard Monitoring Plan

State or EPA(FL only) will review & and approve or State or EPA(FL only) will review & and approve or ask system to modify their SMP.ask system to modify their SMP.

If the State or EPA(FL only) does not approve or If the State or EPA(FL only) does not approve or contact the system to modify the SMP within 12 contact the system to modify the SMP within 12 months from the date it was due, the system can months from the date it was due, the system can consider the plan approved consider the plan approved

Conduct Standard Monitoring in accordance with the Conduct Standard Monitoring in accordance with the plan.plan.

Next Steps after IDSE Plan SubmittalNext Steps after IDSE Plan Submittal

Once SMP is Approved, Conduct 12 months of Once SMP is Approved, Conduct 12 months of monitoring based on Standard Monitoring Planmonitoring based on Standard Monitoring Plan

Determine Stage 2 Compliance Monitoring LocationsDetermine Stage 2 Compliance Monitoring Locations Use protocol in IDSE Guidance Manual (Chapter 7)Use protocol in IDSE Guidance Manual (Chapter 7) From IDSE Results and Stage 1 Results during Standard From IDSE Results and Stage 1 Results during Standard

MonitoringMonitoring

Prepare and submit IDSE Report Prepare and submit IDSE Report Stage 2 Monitoring PlanStage 2 Monitoring Plan Deadline – depends on schedule (3 months from deadline for Deadline – depends on schedule (3 months from deadline for

completion of IDSE monitoring)completion of IDSE monitoring)

Begin Stage 2 Compliance Monitoring – (start date Begin Stage 2 Compliance Monitoring – (start date based on system type and size) based on system type and size)

Stage 2 Routine Compliance Stage 2 Routine Compliance MonitoringMonitoring

Determining Stage 2 Compliance Monitoring Sites Determining Stage 2 Compliance Monitoring Sites (Worsheet 7.2)(Worsheet 7.2)

Stage 2 Compliance Monitoring Site Selection Stage 2 Compliance Monitoring Site Selection Protocol (Exhibit 7.7)Protocol (Exhibit 7.7)

How to Prepare a IDSE ReportHow to Prepare a IDSE Report

Use Form 7 of the IDSE Guidance Manual (Chapter 7) http://www.epa.gov/safewater/disinfection/stage2http://www.epa.gov/safewater/disinfection/stage2 Submit by mail or email to EPASubmit by mail or email to EPA

• Email to: stage2mdbp@epa.govEmail to: stage2mdbp@epa.gov

• Mail to: Stage 2 DBPR Mail to: Stage 2 DBPR US EPA – IPMCUS EPA – IPMC

PO Box 98PO Box 98

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

Submit Updated Distribution Schematic Showing:Submit Updated Distribution Schematic Showing: Locations of SourcesLocations of Sources Entry PointsEntry Points Storage FacilitiesStorage Facilities Stage 2 Compliance Monitoring LocationsStage 2 Compliance Monitoring Locations

System RecordkeepingSystem Recordkeeping

Must keep a copy of their Standard Monitoring plan Must keep a copy of their Standard Monitoring plan and IDSE report for 10 years after date of submittal and IDSE report for 10 years after date of submittal and make available for review by the publicand make available for review by the public

CCR must include the range of sample results from CCR must include the range of sample results from the IDSE monitoring in same calendar year the IDSE monitoring in same calendar year as sampling occurredas sampling occurred

Complete ScheduleComplete Schedule

Part 2 of the Stage 2 Rule - Part 2 of the Stage 2 Rule -

Compliance MonitoringCompliance Monitoring

2012 and Beyond2012 and Beyond

Stage 2 Compliance MonitoringStage 2 Compliance Monitoring(2012 and Beyond)(2012 and Beyond)

MCL Compliance will be calculated based on LRAAMCL Compliance will be calculated based on LRAA

Operational Evaluation Levels – predicts whether Operational Evaluation Levels – predicts whether you will have an MCL violation in the next monitoring you will have an MCL violation in the next monitoring period. 141.626(a)period. 141.626(a)

Operational Evaluation LevelsOperational Evaluation Levels(2012 and Beyond)(2012 and Beyond)

Reg Language: 141.626(a)Reg Language: 141.626(a) You have exceeded the OEL at any monitoring location where the sum You have exceeded the OEL at any monitoring location where the sum

of the 2 previous quarters’ TTHM results plus twice the current quarter’s of the 2 previous quarters’ TTHM results plus twice the current quarter’s TTHM result, divided by 4 to determine an average, exceeds 0.080 TTHM result, divided by 4 to determine an average, exceeds 0.080 mg/L, or where the sum of the 2 previous quarters’ HAA5 results plus mg/L, or where the sum of the 2 previous quarters’ HAA5 results plus twice the current quarter’s HAA5 result, divided by 4 to determine an twice the current quarter’s HAA5 result, divided by 4 to determine an average exceeds 0.060 mg/L.average exceeds 0.060 mg/L.

Example (for TTHMs): current quarter = Q2Example (for TTHMs): current quarter = Q2

(Q4 +Q1) + 2*(Q2)(Q4 +Q1) + 2*(Q2) 44

(0.070 + 0.060) + 2*(0.100) (0.070 + 0.060) + 2*(0.100) = 0.0825 mg/L = 0.0825 mg/L4 4

OEL = 0.0825 ≥ 0.080 mg/L OEL EXCEEDED!

If OEL Is Exceeded...If OEL Is Exceeded...

Must conduct an Operational Evaluation and submit a written report of the evaluation to the State no later than 90 days after being notified of the analytical result that causes you to exceed the OEL.

Examination of System Treatment and Examination of System Treatment and Distribution Operational Practices including:Distribution Operational Practices including:

Excess Storage CapacityExcess Storage Capacity Distribution System FlushingDistribution System Flushing Changes in Sources or Source Water QualityChanges in Sources or Source Water Quality Treatment Changes or Problems that may contribute to Treatment Changes or Problems that may contribute to

TTHM and HAA5 FormationTTHM and HAA5 Formation

Summary of Stage 2 RequirementsSummary of Stage 2 Requirements

Determine IDSE Option (VSS, 40/30, SSS, or SMP)

Submit IDSE (40/30 Cert, SSS, or SMP)

Once ApprovedVSS – continue monitoring Stage 1(if applicable)40/30 – continue monitoring Stage 1(if applicable)

SSS (model) – conduct monitoring (continue Stage 1)SMP – conduct monitoring (continue Stage 1)

After monitoring is complete, select new monitoring locations (out of IDSE and Stage 1 sites)

Put together Stage 2 Monitoring Plan (IDSE Report)

Stage 2 Compliance Monitoring & OELs

Contact Info:Contact Info:

Amy NewboldAmy NewboldEPA Region 4 EPA Region 4

Drinking Water SectionDrinking Water Section (404) 562-9482 (404) 562-9482

Newbold.Amy@epa.govNewbold.Amy@epa.govoror

Region4Stage2@epa.govRegion4Stage2@epa.gov