Systems Working Together to Comply with New LT2/Stage 2 M/DBPRs KY & TN Wholesale and Consecutive System Case Study Scenarios* Jan C. Routt Jan Routt &

Systems Working Together to Comply with New LT2/Stage 2 M/DBPRs KY & TN Wholesale and Consecutive

System Case Study Scenarios*

Jan C. RouttJan C. Routt

Jan Routt & Associates, LLCJan Routt & Associates, LLC

KY-TN Joint Water Professionals ConferenceKY-TN Joint Water Professionals Conference

Chattanooga, Tennessee Chattanooga, Tennessee

July 10, 2006July 10, 2006

*adapted from original presentation, photos omitted for web posting.*adapted from original presentation, photos omitted for web posting.

Implementation Schedule *

TreatmentInstallation

Crypto monitoring

Treatment Installation

Crypto monitoring

TreatmentInstallation

Crypto monitoring

E. coli

Possible Extension

Possible Extension

IDSE

IDSE

IDSE

IDSE

* Includes associated consecutive systems

Possible ExtensionReview

submission

Reviewsubmission

Reviewsubmission

Reviewsubmission

Compliance

1

2

3

4

LT2 Plan or bin classification dueStage 2 IDSE Plan or report due

2006 201320122007 2010 201120092008 2014 2015 2016

2006 201320122007 20092008 2014 2015 2016

Possible ExtensionTreatment Installation

Compliance(if no Crypto Monitoring)

Compliance(if Crypto Monitoring)

Compliance

Compliance

2010 2011

Crypto monitoring

WE ARE HERE

New DefinitionsNew Definitions Combined distribution system (CDS)Combined distribution system (CDS) – Interconnected – Interconnected

distribution system consisting of the distribution system distribution system consisting of the distribution system of wholesale systems and consecutive systems that of wholesale systems and consecutive systems that receive finished water.receive finished water.

Consecutive systemConsecutive system – PWS that receives some or all – PWS that receives some or all of its finished water from one or more wholesale of its finished water from one or more wholesale systems.systems.

Wholesale systemWholesale system – PWS that treats source water as – PWS that treats source water as necessary to produce finished water and then delivers necessary to produce finished water and then delivers some or all of that finished water to another PWS.some or all of that finished water to another PWS.

Finished waterFinished water – Water introduced into the distribution – Water introduced into the distribution system of a PWS intended for distribution and system of a PWS intended for distribution and consumption without further treatment, except as consumption without further treatment, except as necessary to maintain water quality in the distribution necessary to maintain water quality in the distribution system.system.

40 CFR 141.240 CFR 141.2

Combined Distribution SystemsCombined Distribution Systems

Combined DistributionSystem

Treatment Plant

River

Wholesale System100,000100,000

Wholesale and Consecutive System

10,000

Consecutive System50,00050,000

System A System B System C

TreatmentPlant

River

LT2LT2

LT2LT2

Subpart H (SW or GWUDI) systems could end up on different Subpart H (SW or GWUDI) systems could end up on different schedules for LT2 source monitoring and IDSE/Stage 2 schedules for LT2 source monitoring and IDSE/Stage 2 disinfection byproduct monitoring and treatment disinfection byproduct monitoring and treatment implementationimplementation

LT2 ESWTR Surface Source LT2 ESWTR Surface Source Water MicrobialsWater Microbials

Cryptosporidium, E.ColiCryptosporidium, E.Coli and Turbidity and Turbidity2 years monthly testing2 years monthly testing to determine source to determine source

treatment treatment requirements, requirements, Testing cost ~ $25,000-$40,000 per source Testing cost ~ $25,000-$40,000 per source “ “grandfather” acceptable data, or grandfather” acceptable data, or Agree to provide full treatmentAgree to provide full treatment

LT2 Source Monitoring CDS Requirements– 1 LT2 Source Monitoring CDS Requirements– 1 year monthly Crypto/E.Coli/Turbidity samplingyear monthly Crypto/E.Coli/Turbidity sampling Only applies to surface water/GUDI systems Only applies to surface water/GUDI systems Population of largest system receiving water determines Population of largest system receiving water determines

LT2 source monitoring schedule.LT2 source monitoring schedule. If buying water, or considering buying water, from a SW If buying water, or considering buying water, from a SW

provider, advisable to inquire as to LT2 monitoring and provider, advisable to inquire as to LT2 monitoring and treatment status. treatment status.

Treatment Technique compliance criteria & tracking not Treatment Technique compliance criteria & tracking not yet clearly establishedyet clearly established

Systems providing water to large combined systems via Systems providing water to large combined systems via current or planned advanced treatment processes may current or planned advanced treatment processes may want to go ahead with bin testing rather than agreeing to want to go ahead with bin testing rather than agreeing to provide maximum treatment to avoid monitoringprovide maximum treatment to avoid monitoring

Cost of PN for future TT violation in case of treatment Cost of PN for future TT violation in case of treatment failure would be substantialfailure would be substantial

Stage 2 Stage 2 Disinfection ByproductsDisinfection Byproducts Rule Rule Distribution SystemDistribution System Monitoring Monitoring

Initial Distribution System Evaluation Initial Distribution System Evaluation IDSE IDSE Stage 2 Stage 2

Trihalomethanes & Haloacetic Acid5 – 1 year Trihalomethanes & Haloacetic Acid5 – 1 year testing at multiple new sites every 60 – 90 daystesting at multiple new sites every 60 – 90 days

Number samples based on system populationNumber samples based on system populationEntry, Average and Maximum formation sites Entry, Average and Maximum formation sites ~$15,000-$85,000 added testing costs for one year~$15,000-$85,000 added testing costs for one year

Stage 1 testing & compliance continues based on Stage 1 testing & compliance continues based on system average through 2011 at leastsystem average through 2011 at least

Stage2/IDSE CDS multiple samples per 60 or Stage2/IDSE CDS multiple samples per 60 or 90 days for 1 year in addition to Stage 190 days for 1 year in addition to Stage 1

Combined DistributionSystem

Treatment Plant

River


Consecutive System10,000

Consecutive System50,000


TreatmentPlant

River

IDSE/Stage 2

Treatment Plant

River


Wholesale and Consecutive System

10,000

Consecutive System50,00050,000


TreatmentPlant

River

LT2LT2

LT2LT2

Subpart H (SW or GWUDI) systems could end up on different Subpart H (SW or GWUDI) systems could end up on different schedules for LT2 source monitoring and IDSE/Stage 2 schedules for LT2 source monitoring and IDSE/Stage 2 disinfection byproduct monitoring and treatment disinfection byproduct monitoring and treatment implementationimplementation

IDSE/Stage 2

IDSE/Stage 2 Distribution Disinfection IDSE/Stage 2 Distribution Disinfection Byproducts --General RequirementsByproducts --General Requirements

Purpose of IDSEs:Purpose of IDSEs: Determine locations of high TTHM and HAA5 Determine locations of high TTHM and HAA5

concentrations throughout distribution systemconcentrations throughout distribution system Results are used in conjunction with Stage 1 Results are used in conjunction with Stage 1

DBPR compliance monitoring to identify and DBPR compliance monitoring to identify and select Stage 2 DBPR compliance monitoring select Stage 2 DBPR compliance monitoring locations (used for LRAA effective 2012 or later)locations (used for LRAA effective 2012 or later)

Every PWS must perform separate Every PWS must perform separate IDSE and ReportIDSE and Report

Stage 2 sampling may go back to Stage 2 sampling may go back to combined system—minimum of 1 combined system—minimum of 1 sample per systemsample per system

141.600141.600

Stage 2 DBPRStage 2 DBPR

VSS Waiver

40/30 Certification

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 &/or New Data May Apply

Stag

e 1 con

tinu

es

Stage 2 DBPRStage 2 DBPR

VSS Waiver

40/30 Certification

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 &/or New Data May Apply

Prior data

1.5 x SMP Model

0.2 x SMP

Stag

e 1 con

tinu

es

NO

IDSE

TTHM and HAA5 Standard MonitoringTTHM and HAA5 Standard Monitoring(1)(1) For Subpart H systems and systems that purchase Subpart H waterFor Subpart H systems and systems that purchase Subpart H water

Population Frequency TotalNear EP

ARTHigh

TTHMHigh HAA5

<500 consecutive 1 (during peak

historical month)(2)

2 1 - 1 -

<500 non-consecutive2 - - 1 1

500-3,300 consecutive

4 (every 90 days)

2 1 - 1 -

500-3,300 non-consecutive

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(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.

Challenges for Consecutive Challenges for Consecutive SystemsSystems

Receive water that has already been treated Receive water that has already been treated May contain DBPsMay contain DBPs May contain high levels of precursors and disinfectantsMay contain high levels of precursors and disinfectants

BATs for systems with their own source focus on BATs for systems with their own source focus on precursor removalprecursor removal Not an option for consecutive systemsNot an option for consecutive systems

Stage 2 DBPR introduces new Stage 2 DBPR introduces new BATs for consecutive systemsBATs for consecutive systems Management of distribution system and storage Management of distribution system and storage Chloramination Chloramination Consecutives and wholesalers work together for Consecutives and wholesalers work together for

best alternativesbest alternatives

Challenges for Consecutive SystemsChallenges for Consecutive Systems States have taken different approaches in States have taken different approaches in

pastpast May lack data to determine appropriate May lack data to determine appropriate

monitoring locations for Stage 2 DBPRmonitoring locations for Stage 2 DBPR May not be eligible for VSS Waiver or May not be eligible for VSS Waiver or

40/30 Certification under IDSE if lacking data40/30 Certification under IDSE if lacking data• Would need to do Standard Monitoring or SSSWould need to do Standard Monitoring or SSS

Work with wholesalerWork with wholesaler• May have taken samples in consecutive system’s May have taken samples in consecutive system’s

distribution systemdistribution system• System-specific/state-specific regulatory System-specific/state-specific regulatory

interpretations may applyinterpretations may apply

Tennessee Regulatory Overview & Case Study Examples

TTennessee Stage 1 Regulations & Case ennessee Stage 1 Regulations & Case Study ExamplesStudy Examples

Consecutives in combined systems have been included Consecutives in combined systems have been included in compliance DBP monitoring and calculations since in compliance DBP monitoring and calculations since 1999 1999

All systems required to test since 2004--except where All systems required to test since 2004--except where small systems are surrounded by larger systems (ex. small systems are surrounded by larger systems (ex. apartment systems) apartment systems)

<500 population systems are encouraged to monitor <500 population systems are encouraged to monitor this summer to qualify for VSS waiver. this summer to qualify for VSS waiver.

No chloramines allowed in Tennessee to date. No chloramines allowed in Tennessee to date. Many systems are in compliance using optimized Many systems are in compliance using optimized

treatment with alternate in-plant pre-filter disinfection treatment with alternate in-plant pre-filter disinfection (H(H22OO22, enhanced coagulation, P-carbon, G-carbon), enhanced coagulation, P-carbon, G-carbon)

Some large systems will qualify for 40/30 certificationSome large systems will qualify for 40/30 certification

TDEC [email protected] TDEC [email protected]

Tennessee on the New RegsTennessee on the New Regs Most TN ground water systems and even some large subpart Most TN ground water systems and even some large subpart

H systems will qualify for the 40/30 certification. (One TN field H systems will qualify for the 40/30 certification. (One TN field office was already issuing 40/30 certifications in April 06.)office was already issuing 40/30 certifications in April 06.)

Systems need to be aware that IDSE System Specific Studies Systems need to be aware that IDSE System Specific Studies (Modeling or prior DBP data) will be reviewed by the EPA and (Modeling or prior DBP data) will be reviewed by the EPA and not the states.not the states.

Tennessee will expect combined distribution systems to Tennessee will expect combined distribution systems to coordinate sampling, so that, for the most part, everyone coordinate sampling, so that, for the most part, everyone samples on the same days in order to make the data samples on the same days in order to make the data comparable.comparable.

Systems encouraged to work closely with the state laboratory Systems encouraged to work closely with the state laboratory certification officers to minimize errors inherent to method 555.2 certification officers to minimize errors inherent to method 555.2 used for haloacetic acids. See the August 18, 2003 table V-19 used for haloacetic acids. See the August 18, 2003 table V-19 Federal Register proposals for details. Surrogate recoveries Federal Register proposals for details. Surrogate recoveries and other factors need to be looked at in regard to lab results.and other factors need to be looked at in regard to lab results.

TDEC Contact: [email protected]

Tennessee on the New RegsTennessee on the New Regs

Systems need to be aware that they should Systems need to be aware that they should sample sample early in the compliance periodearly in the compliance period, and insist on , and insist on analytical results as soon as possible, so that the analytical results as soon as possible, so that the system can collect additional samples to address system can collect additional samples to address abnormally high, or questionable, analytical results abnormally high, or questionable, analytical results before compliance period ends.before compliance period ends.

Systems need to be aware that Stage 2 Rules Systems need to be aware that Stage 2 Rules revise the Stage 1 Rules to require TOC sampling revise the Stage 1 Rules to require TOC sampling at plants using non-conventional filtration to qualify at plants using non-conventional filtration to qualify for reduced monitoring.for reduced monitoring.


Tennessee on the New RegsTennessee on the New Regs

Because many systems will have to Because many systems will have to conduct public notice, the health effects conduct public notice, the health effects issues discussed by the EPA on page 405 issues discussed by the EPA on page 405 and 406 of the January 2006 Federal and 406 of the January 2006 Federal Register in regard to colon and rectal Register in regard to colon and rectal cancers and negative reproductive cancers and negative reproductive outcomes could be included in the public outcomes could be included in the public notices to better inform customers of notices to better inform customers of systems with MCL violations. systems with MCL violations.


Nontraditional water systemsNontraditional water systems

Nashville Water Department West Wilson W.D.

Brentwood Water Dept. “Non-Traditional

Water Systems”

-Property Owners

-MHP

Total in CDS: 62

Source: SDWIS and TN DWS, (compiled by R-IV EPA)

One County – 89 pubic water supplies

\

Query FormSearch the SDWIS Database

Query FormSearch the SDWIS Database

http://www.epa.gov/enviro/html/sdwis/sdwis_query.html

Safe Drinking Water Query Form for the State of Tennessee

4 water providers; 85 purchasers

4 water providers; 85 purchasers over 500 population –to do IDSE on schedule of largest wholesaler

Less than 500 population may qualify for Very Small System Waiver if have TTHM/HAA5 data –— May need to sample this summer…. contact TDEC for more information

34 systems <500 population may qualify for VSS Waiver with DBP results

Knoxville Utilities Water SystemKnoxville Utilities Water System Large wholesaling SW System (population Large wholesaling SW System (population

190,324) 190,324) Low TOC source (Tennessee River)Low TOC source (Tennessee River)

Bin 1 Crypto—with “grandfather-able” dataBin 1 Crypto—with “grandfather-able” data Conventional clarification treatment, Conventional clarification treatment,

chlorine dioxide/free chlorinechlorine dioxide/free chlorine One consecutive with multiple wholesalersOne consecutive with multiple wholesalers

• Other wholesalers have 40/30 CertificationsOther wholesalers have 40/30 Certifications All assigned to same Schedule 1 CDSAll assigned to same Schedule 1 CDS

KUB W1 CS1(SG)

W2(NM)

W3(JC)

W3(SV) W4

(NP)

CS2(DD)

Knoxville DBP history -> LT2/Stage 2 Knoxville DBP history -> LT2/Stage 2 IDSEIDSE

Free chlorinated system—close to 40/30Free chlorinated system—close to 40/30 Max month September – DBPs sampled in Max month September – DBPs sampled in

special studiesspecial studies Using fluoride tracers to measure retention Using fluoride tracers to measure retention

time & select SMP IDSE sitestime & select SMP IDSE sites automatically monitored – fluoride probes automatically monitored – fluoride probes

configured with data loggersconfigured with data loggers time for non-fluoride treated water to reach time for non-fluoride treated water to reach

points in system to track water retention time points in system to track water retention time Studies to extend into consecutive systemStudies to extend into consecutive system

Summary of KUB Fluoride Tracer Summary of KUB Fluoride Tracer Studies -- Setup & Results Studies -- Setup & Results

Six probes and data loggersSix probes and data loggers Four separate testing events to-dateFour separate testing events to-date

North, South, East & West system areasNorth, South, East & West system areas Sites selected from hydraulic model and general system Sites selected from hydraulic model and general system

knowledgeknowledge Track time for fluoride level changesTrack time for fluoride level changes

drop after shutting off fluoride at plant drop after shutting off fluoride at plant return after turning back on at plantreturn after turning back on at plant

Very Interesting findings– an excellent tool.Very Interesting findings– an excellent tool. Making distribution operational changes based on test findingsMaking distribution operational changes based on test findings

Additional studies plannedAdditional studies planned Repeat all tracer tests (as time allows prior to IDSE plan deadline)Repeat all tracer tests (as time allows prior to IDSE plan deadline) Longer holding-time SDS for comparisonLonger holding-time SDS for comparison

Kentucky Regulations & Kentucky Regulations & Case Study ExamplesCase Study Examples

Kentucky Regulations & Case Study Kentucky Regulations & Case Study ExamplesExamples

Consecutives in combined systems have been Consecutives in combined systems have been included in Stage 1 compliance monitoring and included in Stage 1 compliance monitoring and compliance tabulations of the combined systems compliance tabulations of the combined systems (wholesaler and purchaser) since 1990.(wholesaler and purchaser) since 1990.

Pre-chlorination has been required for most partPre-chlorination has been required for most part Few chloraminating systems (larger, some Few chloraminating systems (larger, some

seasonal)seasonal) State guidance for moving point of chlorination State guidance for moving point of chlorination

and for conversion to chloraminesand for conversion to chloramines

OwentonTriVillage

96

164

water flow60%70%

111

•THM/HAA compliance = average of four sites per “joint” (or combined) system

CombinedCombined ConsecutiveConsecutive Systems have “joint” responsibility Systems have “joint” responsibility for DBP formation and control (under current KY regs)for DBP formation and control (under current KY regs)

Buyer, purchaser, Consecutive

Seller, producer, Wholesaler

Wholesaler A(<10K):Wholesaler A(<10K): SW free SW free chlorine or chloramine chlorine or chloramine seasonal, variableseasonal, variable

Consecutive B(<10K):Consecutive B(<10K): purchased & purchased & rechlorinatedrechlorinated

Wholesaler C (>10K): Wholesaler C (>10K): GW & free chlorine GW & free chlorine WholesalerWholesaler D (<10K): D (<10K): GW & free chlorineGW & free chlorine

WholesalerWholesaler E (>10K,<50K) SW & E (>10K,<50K) SW & chloramines, no yearly free chlorination; chloramines, no yearly free chlorination; water may be purchased from supplier F water may be purchased from supplier F or G. or G.

Wholesaler G(>100) SW & Wholesaler G(>100) SW & chloramines) yearly brief free chloramines) yearly brief free chlorination. Breakpoint free chlorination. Breakpoint free chlorinated as needed @ chlorinated as needed @ Consec B’s master meter for Consec B’s master meter for nitrification control. nitrification control.

WholesalerWholesaler F(>50K <100K) F(>50K <100K) SW & chloramines; SW & chloramines; yearly brief free yearly brief free chlorinationchlorination

Some systems are Some systems are already meeting already meeting LRAAs (ground LRAAs (ground water and water and chloraminating chloraminating systems) and systems) and others have a way others have a way to go.to go.

>50K<50K

>100K

Intermittent supply connections

Chloramines

Free chlorine

Average Yearly THM & HAA Levels

0

0.02

0.04

0.06

0.08

0.1

0.12

0.14

0.16

1980 1984 1988 1992 1996 2000

TH

Ms/

HA

As

(mg

/l)

Ferric ChlorideLowered/Raised

Coagulation pH

Alum at high pH

Ferric PACL

Pre-Chlorine dioxide Intermediate chlorination

Chloramines

Partnership Turbidity Optimization

Distribution Free Chlorine

Increased # max sample points Decreased # max sample points

2004

Even large (>300K) system Even large (>300K) system (including multiple consecutives)(including multiple consecutives) in compliance using pre-filter Chorine, optimized coagulation in compliance using pre-filter Chorine, optimized coagulation

and distribution and distribution ChloraminesChloramines

EVEN LRAAs

Chloramines

0

100

200

300

400

500

600

THM 10/99

THM 8/99

Free Chlorinated System DBPSFree Chlorinated System DBPS

1stQ/04 2ndQ/04 3rdQ/04

4th Q/04 1stQ/05

2ndQ/05

LRAA

Max THM 54 103 142 106 87 61 101

Max HAA 48 68 57 90 73 52 66

Wholesaling systems need to be optimized according to Stage 1 requirements and guidance –prior to chloramine conversionState approvals, benchmarking required prior to change impacting treatment CTDistribution retention time must be managedGo to the max site LRAA if you want to know what the future holds

THMs & HAAs

0.000

0.050

0.100

0.150

Annual Averages

THM Supplier 0.118 0.085 0.077 0.077 0.054 0.065

THM Combined 0.131 0.087 0.091 0.087 0.062 0.074

HAA Supplier 0.040

HAA Combined 0.046

1999 2000 2001 2002 2003 2004

START DATE FOR START DATE FOR MONITORING AND MONITORING AND COMPLIANCE—COMPLIANCE—DETERMINED BY DETERMINED BY LARGEST LARGEST POPULATION POPULATION SYSTEM IN A SYSTEM IN A COMBINED SYSTEM.COMBINED SYSTEM.

States may use States may use knowledge of knowledge of system to decide system to decide whether a smaller whether a smaller system is system is considered considered consecutive of the consecutive of the larger for this larger for this purpose of IDSE/S2 purpose of IDSE/S2 schedulingscheduling

..

>50K<50K

>100K

Intermittent supply connections

Continuous, relatively small volume connections

Where the Where the consecutive consecutive system lines are system lines are drawn has huge drawn has huge implication for implication for smaller systems’ smaller systems’ compliance, labcompliance, lab

workloads and workloads and sample sample coordination by coordination by multiple utilities.multiple utilities.

<50K

>100K

<50K

>50K

How many samples…when?

24 Systems: (>100Klargest): IDSE 252 --> 54 Stage 2 ISDE site plans due 6 months after promulgation

<50K

>100K

<50K

>50K

CDS Schedule 4 (<10K SW &GW)

CDS Schedule 2 (<100K >50K)

CDS : (>100K largest)


For iIlustration purposes only-- All CDS assignments must be verified by KYDOW

<50K

>100K

<50K

>50K


CDS Schedule 2 (<100K >50K)

CDS Schedule 1: (>100K largest)


CDS Schedule 1: (>100K largest)

>100K

<50K

<50K


For iIlustration purposes only-- All CDS assignments must be verified by KYDOW

IDSE Standard Monitoring Plan – Case Study IDSE Standard Monitoring Plan – Case Study Louisville Water Company & ConsecutivesLouisville Water Company & Consecutives

LWC Large Wholesaling (Population 349,000)LWC Large Wholesaling (Population 349,000) Surface Water Source (Ohio River, Moderate TOC)Surface Water Source (Ohio River, Moderate TOC) Two WTPs conventional treatment plus RBI Two WTPs conventional treatment plus RBI Chlorine,ChloraminesChlorine,Chloramines Multiple Consecutive Systems with multiple wholesalersMultiple Consecutive Systems with multiple wholesalers 4 separate PWS assigned to LWC CDS4 separate PWS assigned to LWC CDS Consecs included in Stage 1 DBP complianceConsecs included in Stage 1 DBP compliance Contract lab for TTHM & HAA5 testingContract lab for TTHM & HAA5 testing

LWC conducting IDSEs for consecutivesLWC conducting IDSEs for consecutives Coordinated w/LWC IDSE/Stage 2 on Schedule 1Coordinated w/LWC IDSE/Stage 2 on Schedule 1

LWCW1

CS1

CS3

CS5

CS4

W2

W3

CS2 W4

W5 W6

LWCW1

CS1

CS3

CS4

W2

W3

CS2

IDSE PlansIDSE Plans Plan must be submitted according by October 1 for Schedule Plan must be submitted according by October 1 for Schedule

1 systems to include (Use Forms from IDSE Guidance 1 systems to include (Use Forms from IDSE Guidance Manuals-filled in examples are included)Manuals-filled in examples are included) System ID & descriptionsSystem ID & descriptions Description of processes to select sites, data summaries Description of processes to select sites, data summaries

usedused Sites IDs with justifications—assess available data & sites Sites IDs with justifications—assess available data & sites

in context of known hydraulicsin context of known hydraulics Peak Historical Month BasisPeak Historical Month Basis Schedule including sampling during max historical monthSchedule including sampling during max historical month Schematic – sources, entry points, storage facilities, Schematic – sources, entry points, storage facilities,

pressure zones, pumps locations, SMP and Stage 1 Sites pressure zones, pumps locations, SMP and Stage 1 Sites (map or schematic scale, minimize use of known (map or schematic scale, minimize use of known landmarks for security)landmarks for security)

May review larger, complex systems with State prior to May review larger, complex systems with State prior to submittalsubmittal

Finding Maximum DBP MonthFinding Maximum DBP Month May be May be

selected selected based on based on historically historically highest THMs highest THMs or HAA5s or or HAA5s or water water temperaturetemperature

0.0000

0.0100

0.0200

0.0300

0.0400

0.0500

0.0600

TTHM (mg/L)

HAA5 (mg/L)

TTHM (mg/L)

HAA5 (mg/L)

TTHM (mg/L)

HAA5 (mg/L)

TTHM (mg/L)

HAA5 (mg/L)

Highest historical = 3rd Quarter (July)

Finding Maximum DBP MonthFinding Maximum DBP Month May be selected May be selected

based on historically based on historically highest THMs or highest THMs or HAA5s or water HAA5s or water temperaturetemperature

Other factors may Other factors may come into play as come into play as well… TOC, pH, well… TOC, pH, hydraulics or hydraulics or treatment changestreatment changes 0.0000

0.0100

0.0200

0.0300

0.0400

0.0500

0.0600

TTHM (mg/L)

HAA5 (mg/L)

TTHM (mg/L)

HAA5 (mg/L)

TTHM (mg/L)

HAA5 (mg/L)

TTHM (mg/L)

HAA5 (mg/L)

Highest historical DBP = 3rd Quarter (July),

Highest temperature = Aug

0.0

5.0

10.0

15.0

20.0

25.0

30.0

Temperature (deg C) pH TOC (mg/L)

Stage 1 & IDSE SchedulingStage 1 & IDSE Scheduling Pop Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Total

LWC Wholesaler 836,925

Stage 1 18 18 18 18 72

IDSE SM 24 24 24 24 24 24 144

Consec 1 4,290

Stage 1 1 1 1 1 4

IDSE SM 4 4 4 4 4 20

Consec 2 15,717

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Consec 3 12,823

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Consec 4 12,500

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Total 22 40 62 40 22 40 62 44 332



Stage 1 17 17 17 17 68

IDSE SM 24 24 24 24 24 24 144

Consec 1 4,290

Stage 1 1 1 1 1 4

IDSE SM 4 4 4 4 4 20

Consec 2 15,717

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Consec 3 12,823

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Consec 4 12,500

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Total 22 40 62 40 22 40 62 44 332



Stage 1 16 16 16 16 64

IDSE SM 24 24 24 24 24 24 144

Consec 1 4,290

Stage 1 1 1 1 1 4

IDSE SM 4 4 4 4 4 20

Consec 2 15,717

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Consec 3 12,823

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Consec 4 12,500

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Total 22 40 62 40 22 40 62 44 332



Stage 1 15 15 15 15 60

IDSE SM 24 24 24 24 24 24 144

Consec 1 4,290

Stage 1 1 1 1 1 4

IDSE SM 4 4 4 4 4 20

Consec 2 15,717

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Consec 3 12,823

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Consec 4 12,500

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Total 22 40 62 40 22 40 62 44 332



Stage 1 14 14 14 14 56

IDSE SM 24 24 24 24 24 24 144

Consec 1 4,290

Stage 1 1 1 1 1 4

IDSE SM 4 4 4 4 4 20

Consec 2 15,717

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Consec 3 12,823

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Consec 4 12,500

Stage 1 1 1 1 1 4

IDSE SM 8 8 8 8 8 8 48

Total 22 48 70 48 22 48 70 52 380

Analyzing DBP Formation Analyzing DBP Formation Factors and projecting Factors and projecting

Stage 2 complianceStage 2 compliance Keep track of LRAA at Keep track of LRAA at

each siteeach site Re-analyze historical Re-analyze historical

data for DBP FP data for DBP FP insightsinsights

Generally, Generally, chloraminating systems chloraminating systems will experience very little will experience very little DBPs increases with DBPs increases with retention time, HAA5s retention time, HAA5s may decreasemay decrease

Large Chloraminating SW System & Consecutives Louisville Water Stage 1 Sites - LRAAs 2004 & 2005

0.0000

0.0050

0.0100

0.0150

0.0200

0.0250

0.0300

0.0350

0.0400

AvgB2

PlantTap B

PlantTap A

AvgA3

AvgA1

AvgA2

MaxA1

MaxCS 1

MaxCS 3

AvgB1

MaxCS 2

AvgB3

MaxCS 4

MaxCS 5

HAA5 04 HAA5 05 TTHM 04 TTHM 05

7.6

7.7

7.8

7.9

8.0

8.1

8.2

8.3

8.4

0.000

0.005

0.010

0.015

0.020

0.025

0.030

pH

HAA5

TTHM

2.3

2.4

2.5

2.6

2.7

2.8

2.9

0.000

0.005

0.010

0.015

0.020

0.025

0.030

CL2

HAA5

TTHM

Coordinating IDSE Stage 2 Monitoring and Coordinating IDSE Stage 2 Monitoring and Compliance Efforts in Combined SystemsCompliance Efforts in Combined Systems

Meetings to train and planMeetings to train and plan Each PWS must conduct separate IDSE and Each PWS must conduct separate IDSE and

submit plans and reports separatelysubmit plans and reports separately States may allow Combined System DBP States may allow Combined System DBP

sampling for Stage 2 sampling for Stage 2 (2012 or later)(2012 or later) All individual sites will have to meet LRAA at All individual sites will have to meet LRAA at

Stage 2 sites Stage 2 sites Large volume lab economies Large volume lab economies Tracking and Reporting efficienciesTracking and Reporting efficiencies Better water operations understanding and Better water operations understanding and

choices and compliance potential in the long choices and compliance potential in the long termterm

IDSE/Stage 2 sites Where is the oldest water… maps, chlorine residuals.. historic DBP sites & sample results,Representative

Confounding Issues for all systemsConfounding Issues for all systems Under Stage 2 Maximum LRAA sites may need to Under Stage 2 Maximum LRAA sites may need to

move due to system changes.move due to system changes. How do we calculate LRAA compliance that is: How do we calculate LRAA compliance that is:

truly reflective of the water served to a given service truly reflective of the water served to a given service area and area and

still hold systems accountable for minimizing DBPs at a still hold systems accountable for minimizing DBPs at a highest max site?highest max site?

IDSE is a snapshot--make best choices to find IDSE is a snapshot--make best choices to find maximums -- realizing highest LRAA sites/month maximums -- realizing highest LRAA sites/month may/will end up compliance sites/month under may/will end up compliance sites/month under Stage 2Stage 2

Zone for potential variable supply if chlorine same

ChloraminesSurface WaterLower TOC & DBPFPNitrificationBooster Chlorine to Free Chlorinate

Free Chlorine GroundwaterVery low TOC & DBPFPHigher hardness, Fe, Mn

Free ChlorineLimited Surface WaterHigher TOC & DBPFP

??

??IDSE = “Research Project” – lots of sites sampled to find Stage 2 sites for future LRAA compliance

Form 6. Standard Monitoring Plan Page 3 of 6 IV. JUSTIFICATION OF STANDARD MONITORING SITES*

Standard

Monitoring Site ID

(from map)1

SM 1

SM 2

SM 3

SM 4

SM 5

SM 6

SM 7

SM 8

1 Site IDs should match IDs in Section IV and on your distribution system schematic (See Section VII of this form). Attach additional copies of this sheet if you are required to select more than 8 standard monitoring locations or need more room.

IDSE Sample Site Plans, VSS waiver or IDSE Sample Site Plans, VSS waiver or 40/30 certification for Schedule 1 Systems 40/30 certification for Schedule 1 Systems

Due October 1, 2006!!Due October 1, 2006!!

Form 6: Standard Monitoring Plan Page 2 of 6 III. SELECTING STANDARD MONITORING SITES A. Data Evaluated. Put a A@ in each box corresponding to the data that you used to select each type of standard monitoring site. Check all that apply.

Type of Site

Data Type

Near Entry

Pt.

Avg.

Residence Time

High

TTHM

High HAA5

System Configuration

Pipe layout, locations of storage facilities

Locations of sources and consecutive system entry points

Pressure zones

Information on population density

Locations of large customers

Water Quality and Operational Data

Disinfectant residual data

Stage 1 DBP data

Other DBP data

Microbiological monitoring data (e.g., HPC)

Tank level data, pump run times

Customer billing records

Advanced Tools

Water distribution system model

Tracer study

B. Summary of Data.* Provide a summary of additional data you relied on to justify standard monitoring site selection. You are not required to submit original data. (attach additional sheets if needed)

SEE EPA WEBSITE FOR GUIDANCE MANUALS/FORMS, REGS, TRAINING

Form 6: Standard Monitoring Plan Page 1 of 6 I. GENERAL INFORMATION A. PWS Information*

B. Date Submitted

PWSID:

PWS Name:

PWS Address:

City: State: Zip: Population Served:

System Type:

Source Water Type:

Buying / Selling Relationships:

CWS Subpart H Consecutive System

NTNCWS

Ground

Wholesale System

Neither

C. PWS Operations

Residual Disinfectant Type: Chlorine Chloramines Other:_____________

Number of Disinfected Sources: Surface __ GWUDI Ground _ Purchased D. Contact Person* Name: Title: Phone #:

Fax #:

II. IDSE REQUIREMENTS*

A. Number of Sites: B. Schedule

C. Standard Monitoring Frequency

Total:

Near Entry Point:

Schedule 1

Avg Residence Time:

Schedule 2

During peak historical month (1 monitoring

period)

High TTHM:

Schedule 3

Every 90 days (4 monitoring periods)

High HAA5:

Schedule 4

Every 60 days (6 monitoring periods)

Using Guidance Manual Examples to Understand Using Guidance Manual Examples to Understand IDSE Report & Stage 2 Site SelectionIDSE Report & Stage 2 Site Selection

Follow Guidance manual instructions to review Follow Guidance manual instructions to review data and select Proposed Stage 2 sitesdata and select Proposed Stage 2 sites

Use FORM 7 “IDSE Report for Standard Use FORM 7 “IDSE Report for Standard Monitoring”Monitoring”

Sort the data from highest to lowest TTHM LRAA

For each site, sum of results for each sample period and divide by number of sample periods for one year = LRAA

If LRAA TTHM results are under 0.080 mg/L, system is in compliance

Sort data from highest to lowest HAA5 LRAA—(separate spreadsheet)


If LRAA HAA5 results are under 0.060 mg/L, system is in compliance

Compile all the TTHM data inserting columns to spread the data across the 12 month sampling year.

Compile HAA5 data in same format in a separate spreadsheet.

Sort the data from highest to lowest TTHM LRAA


If LRAA TTHM results are under 0.080 mg/L, system is in compliance

Sort data from highest to lowest HAA5 LRAA—(separate spreadsheet)


If LRAA HAA5 results are under 0.060 mg/L, system is in compliance

Use EPA sequence described in Regulation CFR 141.605 and IDSE Guidance Manual to select Stage 2 sites

Report 3 months after IDSE completed—January 1 2009 for largest systems

Stage 2 LRAA compliance will be required after first complete year of testing at new sites

Keep repeating the steps till all Stage 2 sites are selected.

Regional MDBP Team

IPMCE

PA

HQ

E

I T

eam

Primacy Agencies

HQ SSS Review Team

Consecutive PWS

Wholesale PWS

Reporting and Tracking Using Multiple People and Methods for Early Implementation

Effective source selection and use.Effective source selection and use. Optimized DBP precursor removal, Optimized DBP precursor removal,

chlorine/chloramine applications chlorine/chloramine applications Effective distribution operations, Effective distribution operations,

sampling and flushing programs, tank sampling and flushing programs, tank turnover more important than ever.turnover more important than ever.

Extended low flow rural/residential Extended low flow rural/residential areas may need blow offs and/or areas may need blow offs and/or sampling hydrants to provide sample sampling hydrants to provide sample sites and to ensure routine water sites and to ensure routine water turnover.turnover.

Regular tank turnover and problem area flushing are good– BUT it is not allowed to just send flushing crews in advance of DBP samplers----IDSE is looking for representative water.

Take home messagesTake home messages Learn/Know your systems—work together across Learn/Know your systems—work together across Plan IDSE sampling in cooperation with State (EPA), Plan IDSE sampling in cooperation with State (EPA),

wholesale andwholesale and consecutive systems, working together—look at consecutive systems, working together—look at the big picture and exercise best discretionary options.the big picture and exercise best discretionary options.

Apply for VSS Waiver, 40/30 Certification if applicableApply for VSS Waiver, 40/30 Certification if applicable Submit IDSE Plans as requiredSubmit IDSE Plans as required Don’t overlook the obvious (Find and FIX THE HOT SPOTs--so they Don’t overlook the obvious (Find and FIX THE HOT SPOTs--so they

don’t end up as max LRAA sites!)don’t end up as max LRAA sites!) Consider future changes--supply, facilities’ configuration, operations– Consider future changes--supply, facilities’ configuration, operations–

how will they impact DBPs and/or disinfection..or corrosion control??how will they impact DBPs and/or disinfection..or corrosion control?? Line up a dependable labs and keep close track of samples and trendsLine up a dependable labs and keep close track of samples and trends

Complete capital changes in time to meet Stage 2 LRAA Complete capital changes in time to meet Stage 2 LRAA MCLsMCLs

If change is to chloramines; minimize water age, implement a If change is to chloramines; minimize water age, implement a nitrification control plan up front.nitrification control plan up front.

Remember any disinfection change must be carried out with extreme Remember any disinfection change must be carried out with extreme caution…and State approval.caution…and State approval.

Remember CCR reporting requirements Remember CCR reporting requirements

AcknowledgementsAcknowledgements Louisville Water Company & ConsecutivesLouisville Water Company & Consecutives Knoxville Utilities BoardKnoxville Utilities Board Kentucky American WaterKentucky American Water Tennessee Division of Water SupplyTennessee Division of Water Supply Kentucky Division of WaterKentucky Division of Water EPA HQ & Region IV EPAEPA HQ & Region IV EPA

Further Information Contact:Further Information Contact:

Jan Routt & Associates, LLCJan Routt & Associates, LLC (859)537-7750 (859)537-7750

[email protected]@windstream.net website: www.janroutt.comwebsite: www.janroutt.com

Documents

Systems Working Together to Comply with New LT2/Stage 2 M/DBPRs KY & TN Wholesale and Consecutive System Case Study Scenarios* Jan C. Routt Jan Routt &