State of Alaska Implementation of MBDP Rules Carrie Bohan Environmental Program Specialist ADEC DW Program

 Rule promulgated by US EPA December 16, 1998  Adopted by the State of Alaska on September 28, 2001  Effective for surface water systems or GWUDISW systems (Subpart H) serving 10,000+ on January 1, 2002  Effective for surface water or GWUDISW systems serving <10,000, and all ground water systems on January 1, 2004  CWS, NTNCWS and TNCWS using chlorine dioxide Stage 1 D/DBR Basic Requirements

 Basic Requirements  MCLs and monitoring requirements for TTHMs, HAA5s, Bromate, and Chlorite  MRDL for Chlorine, Chloramines and Chlorine Dioxide  Treatment technique for enhanced coagulation/softening to improve precursor removal for conventional filtration plants Stage 1 D/DBR Basic Requirements

 Monitoring Requirements Stage 1 D/DBR CoverageMonitoring FrequencyCompliance TTHM/HAA5 Surface and GWUDISW serving > 10,000 4/plant/quarterRunning Annual Average Surface and GWUDISW serving 500 – 9,999 1/plant/quarterRunning Annual Average Surface and GWUSIDW serving < 500 1/plant/year in month of warmest water temperature Running Annual Average Ground water serving > 10,0001/plant/quarterRunning Annual Average Ground water serving 10,0001/plant/year in month of warmest water temperature Running Annual Average Bromate Ozone plantsMonthlyRunning Annual Average Chlorite Chlorine dioxide plantsDaily at EP to DS, Monthly in DS Daily Chlorine Dioxide Chlorine dioxide plantsDaily at EP to DSDaily Chlorine/ Chloramines All SystemsSame location and frequency as TCR sampling Running Annual Average DBP Precursors Conventional filtration plantsMonthly for TOC and AlkalinityRunning Annual Average Basic Requirements

 Compliance Determination  If monitoring annually, results of one annual sample  If exceed the MCL, must go to quarterly sampling  If monitoring quarterly, average of past four quarters (running annual average)  Monthly samples are averaged quarterly, compliance is based on running annual average of quarterly averages Stage 1 D/DBR Compliance Determination

 Violation Types  MCL Violations  TTHMs, HAA5s, Bromate, Chlorite  MRDL Violations  Chlorine, Chloramines  Treatment Technique Violations  Not meeting Precursor Removal  Monitoring and Reporting Violations  Not collecting any individual sample  Most commonly distribution system chlorine residual  Not submitting reporting forms in a timely fashion  Public Notification Violations  Failure to conduct PN as required for violations  Acute – 24 hours, MCL/TT – 30 days, M/R – 1 year Stage 1 D/DBR Compliance Determination

 Reporting Forms   Quarterly TTHM/HAA5 RAA reports  Quarterly Bromate/Bromide Reports  Quarterly MRDL reports  Quarterly Enhanced Coagulation Reports Stage 1 D/DBR Compliance Determination

 Significant Non-Complier List (SNC)  Monthly Monitoring ( Chlorine residual, MRDL )  A combination of 4 or more MCL or MRDL violations in any 12 consecutive months  A combination of 6 or more MCL, MRDL and Major Monitoring/Reporting violations in any 12 consecutive months  A combination of 10 or more MCL, MRDL, Major and Minor M/R violations in any 12 consecutive months Stage 1 D/DBR Compliance Determination

 Significant Non-Complier List (SNC)  Quarterly Monitoring ( TTHM/HAA5s, Bromate )  A combination of 2 or more MCL, MRDL, Treatment Technique, and Major M/R violations in any 12 consecutive months  A combination of 3 or more MCL, MRDL, Treatment Technique, and Major or Minor M/R violations in any 12 consecutive months  Annual or Less Frequent Monitoring  Failing to collect or report all required samples  If exceed the MCL, go to quarterly monitoring, no violation  Also….  Failure to obtain State approval before making significant changes to existing treatment process Stage 1 D/DBR Compliance Determination

 Significant Non-Complier List (SNC)  All SNC violations for Stage 1 take 12 months to Return to Compliance, or until the end of the quarterly violation  Example... Stage 1 D/DBR Compliance Determination

 Example System A Surface water system serving 425 August 2007 Annual samples TTHM 82 ug/LHAA5 90 ug/L No Violation Must begin quarterly samples Stage 1 D/DBR Compliance Determination TTHMHAA5 Q Q Q Q ug/L 83 ug/L 67 ug/L69 ug/L 78 ug/L88 ug/L 101 ug/L 93 ug/L RAA79 ug/L85.3 ug/L

 Example System A Q System receives an MCL violation for Q Must continue quarterly sampling Stage 1 D/DBR Compliance Determination TTHMHAA5 Q Q Q Q ug/L 83 ug/L 67 ug/L69 ug/L 78 ug/L88 ug/L 101 ug/L 93 ug/L RAA79 ug/L85.3 ug/L

 Example System A Q Stage 1 D/DBR Compliance Determination TTHMHAA5 Q Q Q Q ug/L 67 ug/L 88 ug/L78 ug/L 86 ug/L72 ug/L 69 ug/L 101 ug/L RAA77.5 ug/L83.5 ug/L Second consecutive quarterly MCL violation for HAA5s Qualifies for SNC status

Stage 1 D/DBR Compliance Determination TTHMHAA5 Q Q Q Q ug/L 64 ug/L 68 ug/L51 ug/L 43 ug/L62 ug/L 57 ug/L 86 ug/L RAA66.5 ug/L59.3 ug/L Can take up to 1 year of lower results to bring the RAA below the MCL. Receives quarterly MCL violations until RAA is below the MCL. TTHMHAA5 Q Q Q Q ug/L 67 ug/L 88 ug/L78 ug/L 86 ug/L72 ug/L 69 ug/L 101 ug/L RAA77.5 ug/L83.5 ug/L  Example System A Q4 2008

Q  Example System A Stage 1 D/DBR Compliance Determination TTHMHAA5 Q Q Q Q ug/L 59 ug/L 61 ug/L51 ug/L 47 ug/L66 ug/L 46 ug/L 43 ug/L RAA62 ug/L46.8 ug/L Once RAA is below the MCL, will take one year to come off the SNC List. TTHMHAA5 Q Q Q Q ug/L 64 ug/L 68 ug/L51 ug/L 43 ug/L62 ug/L 57 ug/L 86 ug/L RAA66.5 ug/L59.3 ug/L Q2 2010

 Example System A Stage 1 D/DBR Compliance Determination TTHMHAA5 Q Q Q Q ug/L 59 ug/L 61 ug/L51 ug/L 47 ug/L66 ug/L 46 ug/L 43 ug/L RAA62 ug/L46.8 ug/L In this example, it took 2 years from the initial violation to come off the SNC List. TTHMHAA5 Q Q Q Q ug/L 83 ug/L 67 ug/L69 ug/L 78 ug/L88 ug/L 101 ug/L 93 ug/L RAA79 ug/L85.3 ug/L

Stage 2 D/DBR Compliance Determination  Rule promulgated January 4, 2006  State has 2 years to adopt  January 4, 2008  Have applied for a 2 year extension  January 4, 2010  No early implementation by the State  Until Alaska adopts the rule, systems will work directly with EPA

Stage 2 D/DBR Compliance Determination  Assuming the State adopts in early 2010  All systems will submit 40/30 certifications, VSS waiver requests, Standard Monitoring or System Specific Study plans to EPA  Schedule 1 and 2 systems will conduct Standard Monitoring or System Specific Study sampling and submit the IDSE report to EPA  Schedule 3 and 4 systems will submit IDSE report to ADEC

 Violations Types  Monitoring/Reporting Violations  Failure to submit Monitoring Plan on time  Failure to monitor  MCL violation  LRAA exceeds the MCL  SNC Lists  EPA has not yet determined SNC definitions Stage 2 D/DBR Compliance Determination

 Promulgated December 16, 1998 and January 14, 2005, respectively  Lowered turbidity treatment technique standards  Requires individual filter effluent turbidity monitoring  Follow up activities for exceeding certain triggers  Filter Profile, Filter Self Assessment, Comprehensive Performance Evaluation  Filtered systems must meet 2-log Crypto removal  Increased sanitary survey frequency, no new uncovered finished water storage tanks IESWTR/LT1 Basic Requirements

 Promulgated December 16, 1998 and January 14, 2002, respectively  Lowered turbidity treatment technique standards  Requires continuous individual filter effluent turbidity monitoring  Follow up activities for exceeding certain triggers  Filter Profile, Filter Self Assessment, Comprehensive Performance Evaluation  Filtered systems must meet 2-log Crypto removal  Increased sanitary survey frequency, no new uncovered finished water storage tanks IESWTR/LT1 Basic Requirements

 Types of Violations  Monitoring/Reporting  Failure to conduct daily entry point chlorine residual monitoring**  Failure to conduct distribution system chlorine residual monitoring at the same time and location as monthly bacti**  Failure to conduct daily treated water turbidity monitoring**  Failure to conduct continuous individual filter effluent monitoring  Failure to conduct triggered activity from IFE readings  Failure to submit monthly reports on time  Failure to conduct Disinfection Profile & Benchmark if required  Failure to report turbidity MCL violation within 24 hours IESWTR/LT1 Compliance Determination ** SWTR violations

 Types of Violations  Treatment Technique Violations  Failure to meet 2-log removal of Cryptosporidium  Failure to meet turbidity standards  Alternative filtration – 1.49 NTUs 95% of samples  Direct/Conventional filtration – 0.3 NTUs in 95% of samples  MCL Violations  Exceeding the turbidity MCL  Alternate filtration – 5 NTUs  Direct/Conventional filtration – 1.49 NTUs  Public Notification Violations  Failure to conduct PN as required for violations IESWTR/LT1 Compliance Determination

 Reporting forms   4 Versions  Direct/Conventional systems with 3 or more filters  Continuous IFE turbidity monitoring  Direct/Conventional systems with 1 or 2 filters  Continuous CFE turbidity monitoring in lieu of continuous IFE monitoring  Alternative/slow sand systems  Alternative/slow sand systems with reduced monitoring  Serve less than 500, reduced to one chlorine residual reading per day IESWTR/LT1 Compliance Determination

 Significant Non-Complier List (SNC)  Unfiltered Systems  Systems that fail avoidance criteria and do not install filtration within 18 months  3 or more Major M/R violations in any 12 consecutive months  5 or more Major and/or Minor M/R violations in any 12 consecutive months  Filtered Systems  4 or more TT violations in any 12 consecutive months  6 or more TT and/or Major M/R violations in any in 12 consecutive months  10 or more TT, Major and/or Minor M/R violations in any 12 consecutive months  All SNC violations for SWTRs take 6 months to Return to Compliance IESWTR/LT1 Compliance Determination

 Promulgated January 5, 2006  State has 2 years to adopt  January 5, 2008  Have applied for a 2 year extension  January 5, 2010  No early implementation by the State  All plan reviews for new systems or system improvements are held to LT2 standards  Until Alaska adopts the rule, systems will work directly with EPA LT2 Basic Information

 Assuming the State adopts in early 2010  All systems will submit to EPA  Samples schedules for initial source water monitoring  Results of initial source water monitoring  Notification of uncovered finished water storage tanks  Schedule 1 and 2 systems will submit Bin Classification or mean Crypto sample results to EPA  Schedule 3 system will submit Bin Classification or mean Crypto sample results to ADEC  Schedule 4 systems required to conduct Crypto monitoring will submit sample schedules to ADEC LT2 Rule Adoption

 Violations  Monitoring/Reporting Violations  Failure to submit monitoring plan  Failure to conduct e.coli monitoring  Failure to collect a sample within the 5-day period around a scheduled date (unless extenuating) LT2 Compliance Determination

 Violations  Treatment Technique Violations  Failure to collect Crypto samples to determine bin classification  Failure to provide required treatment by the established compliance date  Failure to meet monthly Crypto inactivation requirements  Ozone or Chlorine dioxide – more than 1 day per month  UV – more than 5% of water delivered  Failure to meet IFE performance criteria for tool box credit  SNC List  EPA has not yet determined SNC definitions LT2 Compliance Determination

 Reporting Forms  New reporting forms are in the works for LT2  Membrane filtration  Direct and indirect integrity testing requirements  UV  Calculated dose, set point approach  Ozone LT2 Compliance Determination

 EPA’s MDBP Website   Quick Reference Guides and Fact Sheets broken down by schedule number  Source Water Monitoring Guide for LT2  UV and Membranes Guidance Manuals for LT2  IDSE Guidance Manual  Simultaneous Compliance Guide for LT2 and Stage 2  Training on using EPA’s Data Collection and Tracking System online More Information