PUBLIC WATER SYSTEM PLAN and EXCEPTION REVIEW Plan Review Team David T. Smith, P.E. Technical Review and Oversight Team Erin Guerra, P.E. Plan and Technical Review Section Water Supply Division

Why Submit Plans? Law Public Health and Safety Plan Review Team Mission: To ensure that public water system construction meets minimum standard public health and operational safety design criteria in compliance with federal and state statute and good engineering practices. Law Texas Health & Safety Code Federal Safe Drinking Water Act

HEALTH and SAFETY …this is why we require review and maintenance! Ready for Pump Replacement? This slide contains pictures of equipment in need of maintenance or replacement.

Who Submits Plans? ALL Public Water Systems* Professional Engineers (P.E.) Licensed in the State of Texas ALL Public Water Systems* Cities, Districts, Non-profit or For-Profit, Wholesale or Retail, or Privately Owned Water Systems * That have 15 service connections or serve 25 or more individuals at least 60 days out of a year.

When Do We Submit Plans? BEFORE STARTING CONSTRUCTION: No person may begin construction on a new public water system before receiving written approval of plans and specifications. §290.39(h)(1) IF SIGNIFICANT CHANGE TO EXISTING SYSTEM IS PLANNED: Significant changes shall not be instituted without prior approval ….§290.39(j)

What’s A Significant Change? Potential Health Hazard: §290.39(j)(1)(B)&(C) Increase or Decrease in Capacity: §290.39(j)(1)(A) ~Distribution ~Treatment ~Production ~Pressure ~Storage This slide contains a picture of ground storage tanks. Potential Health hazard would include treatment changes.

Significant Changes… Distribution Capacity (measured in connections) Distribution expansion, waterlines (in connections) # of new connections <10% total existing connections and does not affect the ability to comply with capacity requirements or involves interconnection with another public water system 290.39(j)(1)(d)

More Significant Changes… Disinfection §290.39(j)(1)(B) Disinfectant Application point Monitoring point Residual §290.39(j)(1)(C) This slide contains a schematic of a surface water treatment plant.

Significant Changes ANY OTHER MATERIAL CHANGES specified by TCEQ. §290.39(j)(1)(E)

Plans & Specs NOT Required CHANGES NOT SIGNIFICANT? Waterline additions less than 10% of the total connections Waterlines subject to ordinance review A) ORDINANCE: Copy of local ordinance or statute requiring submittal to another state agency with its own internal review staff. §290.39(j)(2)(B) B) CERTIFICATION: Written 290 compliance certification by internal staff P.E. C) NOTIFICATION: Letter of notification to TCEQ. §290.39(j)(2)(B)

What To Submit? Written Notification §290.39(h)(2) and/or Cover Letter Submittal Form §290.39(h)(1)(2) Engineering Report §290.39(e)(1) New system, SWTP, or deficiencies Engineering Plans and Technical Specifications §290.39(j)(2)(B) Business Plan §290.39(f) for Privately owned new public water systems Email addresses are considered confidential

Plan Submittal Form Must use unaltered TCEQ form only Use latest revision of the form Can be obtained from TCEQ Webpage Sign and seal the form This slide contains a picture of the TCEQ Plan Review Submittal Form.

ENGINEERING DRAWING Sign, seal, and date each page SEAL This slide contains a picture of an engineer’s drawing, showing the placement of the engineer’s seal. SEAL

CONSTRUCTION SPECIFICATIONS BOUND WITH COVER PAGE SIGNED, SEALED & DATED This slide contains an example of construction specifications submitted to the TCEQ.

What Else Is Submitted? Submit and Receive Approval for Following Prior to Plant Startup and PRIOR to Plan Review Submittal: Exception Request for any changes from rule requirements Pilot study Change in source New filtration rate Alternative process (not conventional filtration) CT* Study – 90 days prior / SWTP _______________________________________ *C = disinfectant residual concentration, T = time

Mail: Deliver: Where Do We Send Plans? Plan Review Team - MC-159 Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087 Deliver: 12015 Park Circle, Bldg. F, 3rd. Floor Austin, TX 78753

How Are Plans Processed? RECEIVE ~ 180 Plans/Month Given a Log Number and Entered into WUD database Administrative Review Assigned to Plan Reviewer Reviewed by Engineering Staff* in order received The average is the 3 year average for 2015, 2016 and 2017.

TYPES OF PROJECTS 2018 This slide contains a chart showing the types of projects received by TCEQ in 2018: wells, 21%; ground water treatment plants, 11%; surface water treatment plants, 2%; Reverse Osmosis – 1% waterlines, 37%; and other, 28%. Other includes tanks not at a designated plant, generators, disinfection, corrosion control treatment and so on.

http://www.tceq.state.Texas.gov/drinking water/planrev.html WEB SITE http://www.tceq.state.Texas.gov/drinking water/planrev.html New: Surface Water Checklists This slide shows the Plan Review page on the TCEQ website. In addition to checklists with what rules are reviewed on a particular submittal, we also have construction notes for typical facility upgrades

Process Related Plans- Reviewed by Technical Review and Oversight Team Disinfection: Chlorination/Chloramination Chlorine Dioxide Ozonation UV Treatment: Conventional filtration Package plants Membranes Ion Exchange Innovative Technologies Each project reviewed on a site specific basis

Exceptions: Proposing Another Way to Meet the Intent of the Rules Plan & Technical Review Section Technical Review and Oversight Team Erin Guerra, P.E. May 2019

Scope Learn the purpose of the FBRR and the procedural requirements of the PWS Learn the procedural requirements to request an exception to propose another way to meet the intent of the rules under 30 TAC 290, Subchapter D

Where do Exceptions Come From? Allowed as described in 30 TAC §290.39 (l) Each request is considered on an individual basis. Must demonstrate that the exception will not compromise the public health or degrade the service or water quality. Any granted exception can be revised or revoked. As a condition of granting the exception the TCEQ may establish site-specific design, operation, maintenance, and reporting requirements for systems.

2018 - Exceptions Received per Rule Section

Procedural Requirements When are exceptions allowed? Who can submit an exception request? What is required in the exception submittal? When do you submit exception requests? Where do you send exception requests?

When are Exceptions Allowed? If a public water system (PWS) does not meet a TCEQ design standard, they may request an exception by proposing another way it can meet the intent of the rules. There are no design standards in the TCEQ regulations for these types of treatments. This Photo by Unknown Author is licensed under CC BY-NC-SA

Who Can Submit Exceptions? Public Water Systems and their representatives For almost any rule between §290.41-.46 Professional Engineers licensed in Texas Pilot study reports - §290.42(g) Alternative Capacity Requirement requests for alternatives to elevated storage - §290.45(g)(5)

What is required in an Exception submittal? TCEQ- 20659 Signed cover letter Proposed alternative, explanation, supporting documentation

What Else Is Submitted? Submit and Receive Approval for Following Prior to Plant Startup and PRIOR to Plan Review Submittal Exception Request for any changes from rule requirements – 90 to 100 days Pilot study Change in source New filtration rate Alternative process (not conventional filtration) CT* Study – 90 days prior / SWTP _______________________________________ *C = disinfectant residual concentration, T = time

When do you submit Exception Requests? Before the PWS is locked into a course of action that will result in a deviation from the rules. To comply in response to an alleged violation noted during a Comprehensive Compliance Inspection (CCI). Before submitting engineering plans and specifications for review and approval.

Where Do You Submit Exception Requests? Technical Review and Oversight Team Plan and Technical Review Section, MC -159 Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087

Process Related Plans Disinfection: Treatment: Conventional filtration Blending Chlorine & Chloramines Chlorine Dioxide Ozone Ultraviolet Treatment: Conventional filtration Package plants Membranes Ion Exchange Innovative Technologies Each project reviewed on a site specific basis

Help with Exception Submittals Used by the public and TCEQ Staff Available on TCEQ Website Updated in 2018 Staff Guidance Documents Documentation required Checklists https://www.tceq.texas.gov/drinkingwater/trot/exception

How Long Does It Take TCEQ to Review the Request? Each exception request is reviewed to ensure that, if granted, the PWS will still deliver safe drinking water to its customers at adequate pressures. Type Timeframe Exceptions 100 days ACRs 90 days Expedited requests are considered but must have a very good reason for the request.

Last Things About Exceptions Any granted exception can be revised or revoked. As a condition of granting the exception the TCEQ may establish site-specific design, operation, maintenance, and reporting requirements for systems.

Financial, Managerial, & Technical (FMT) Assistance If you operate a water or wastewater system and would like to arrange for free financial, managerial, or technical assistance, contact our Financial, Managerial and Technical (FMT) program team: FMT@tceq.texas.gov https://www.tceq.texas.gov/drinkingwater/fmt (512) 239-4691

Small Business & Local Government Assistance Free confidential hotline 1-800-447-2827 http://www.texasenvirohelp.org

Water Supply Mainline: (512) 239-4691 Questions? Water Supply Mainline: (512) 239-4691 Plan Review Website - www.tceq.texas.gov/permitting/water_supply/ud/planrev.html Exception Website - http://www.tceq.texas.gov/drinkingwater/trot/exception Water Supply General Email Box: PDWS@tceq.texas.gov