1. 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 & Associates, LLC
KY-TN Joint Water Professionals Conference
Chattanooga, Tennessee
July 10, 2006
*adapted from original presentation, photos omitted for web posting.

2. Implementation Schedule *
WE ARE HERE
Implementation Schedule *
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
Crypto monitoring
Treatment
Installation
Possible Extension 1
Review
submission
IDSE
Compliance
Crypto monitoring
Treatment
Installation
Possible
Extension 2
Review
submission
IDSE
Compliance
Crypto monitoring
Treatment
Installation
Possible Extension 3
Review
submission
IDSE
Compliance
Compliance
(if Crypto Monitoring)
E. coli
Possible
Extension
Crypto monitoring 4
Review
submission
IDSE
Treatment Installation
Compliance
(if no Crypto Monitoring)
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
LT2 Plan or bin classification due
Stage 2 IDSE Plan or report due
* Includes associated consecutive systems

3. New Definitions
40 CFR 141.2
Combined distribution system (CDS) – Interconnected distribution system consisting of the distribution system of wholesale systems and consecutive systems that receive finished water.
Consecutive system – PWS that receives some or all of its finished water from one or more wholesale systems.
Wholesale system – PWS that treats source water as necessary to produce finished water and then delivers some or all of that finished water to another PWS.
Finished water – Water introduced into the distribution system of a PWS intended for distribution and consumption without further treatment, except as necessary to maintain water quality in the distribution system.
Combined distribution system (CDS): Interconnected distribution system consisting of the distribution systems of wholesale systems and consecutive systems that receive finished water.
Consecutive system: PWS that receives some or all of its finished water from one or more wholesale systems.
Dual sample set: Set of two samples collected at the same time and location, with one sample analyzed for TTHM and the other analyzed for HAA5.
Finished water: Water introduced into the distribution system of a PWS intended for distribution and consumption without further treatment, except as necessary to maintain water quality in the distribution system.
GAC10: Granular activated carbon filter beds with an empty-bed contact time of 10 minutes based on average daily flow and a carbon reactivation frequency of every 180 days, except that the reactivation frequency for GAC10 used as a BAT for compliance with Stage 2 DBPR MCLs under (b)(2) shall be 120 days.
GAC20: granular activated carbon filter beds with an empty-bed contact time of 20 minutes based on average daily flow and a carbon reactivation frequency of every 240 days.
Locational running annual average (LRAA): Average of sample analytical results for samples taken at a particular monitoring location during the previous four calendar quarters.
Wholesale system: PWS that treats source water as necessary to produce finished water and then delivers some or all of that finished water to another PWS.

4. Combined Distribution Systems
Wholesale System
100,000
Wholesale and
Consecutive System
10,000
Consecutive System
50,000
Treatment
Plant
System A
System B
System C
LT2 R i v e r
Treatment
Plant
River
LT2
This is an illustration of a combined distribution system.
In this example, System A sells water to System B, which in turn sells water to System C. System A is the largest system in the combined distribution system. System B has its own source and sells water to System C.
For LT2 system A must comply on schedue 1 (>100K). System B serves 10k in its system and sells to system C which serves 50K population therefore, B must comply monitor its source water and implement treatment on Schedule 2 due to selling water to System C with >50K population.
For Stage 2 DBPR System A complies based on the requirements for a system serving 100,000 people. But because System B purchases water from System A, System B must comply with the Stage 2 DBPR schedule based on the population of the largest system in the combined distribution system, which is System A. Even though System C does not sell water and does not have its own source, it is still required to comply with the schedule of the largest system in the combined distribution system, which is System A.
Bottom line is smaller system sellling water to larger ones need to verify LT2 source testing requirements with state and smaller systems selling water to or buying water from larger systems need to verify their IDSE/Stage 2 schedules with States and /or EPA
Combined Distribution
System
Subpart H (SW or GWUDI) systems could end up on different schedules for LT2 source monitoring and IDSE/Stage 2 disinfection byproduct monitoring and treatment implementation

5. LT2 ESWTR Surface Source Water Microbials
Cryptosporidium, E.Coli and Turbidity
2 years monthly testing to determine source treatment requirements,
Testing cost ~ $25,000-$40,000 per source
“grandfather” acceptable data, or
Agree to provide full treatment
First I will briefly talk about the LT2 Enhanced Surface water treatment rule source water microbial testing –focusing particularly on the Cryptosporidium testing since it is the most challenging and costly—and the results will drive future microbial inactivation and removal requirements.
Next slide please

6. LT2 Source Monitoring CDS Requirements– 1 year monthly Crypto/E
LT2 Source Monitoring CDS Requirements– 1 year monthly Crypto/E.Coli/Turbidity sampling
Only applies to surface water/GUDI systems
Population of largest system receiving water determines LT2 source monitoring schedule.
If buying water, or considering buying water, from a SW provider, advisable to inquire as to LT2 monitoring and treatment status.
Treatment Technique compliance criteria & tracking not yet clearly established
Systems providing water to large combined systems via current or planned advanced treatment processes may want to go ahead with bin testing rather than agreeing to provide maximum treatment to avoid monitoring
Cost of PN for future TT violation in case of treatment failure would be substantial

7. Stage 2 Disinfection Byproducts Rule Distribution System Monitoring Initial Distribution System Evaluation IDSE  Stage 2
Trihalomethanes & Haloacetic Acid5 – 1 year testing at multiple new sites every 60 – 90 days
Number samples based on system population
Entry, Average and Maximum formation sites
~$15,000-$85,000 added testing costs for one year
Stage 1 testing & compliance continues based on system average through 2011 at least

8. Combined Distribution
Stage2/IDSE CDS multiple samples per 60 or 90 days for 1 year in addition to Stage 1
Wholesale System
100,000
Consecutive System
10,000
Consecutive System
50,000
Treatment
Plant
System A
System B
System C R i v e r
Treatment
Plant
River
This is an illustration of a combined distribution system.
In this example, System A sells water to System B, which in turn sells water to System C. System A is the largest system in the combined distribution system. Therefore, System A complies with the Stage 2 DBPR based on the requirements for a system serving 100,000 people. System B has its own source and sells water to System C. Because System B purchases water from System A, System B must comply with the Stage 2 DBPR schedule based on the population of the largest system in the combined distribution system, which is System A. Even though System C does not sell water and does not have its own source, it is still required to comply with the schedule of the largest system in the combined distribution system, which is System A.
Combined Distribution
System
IDSE/Stage 2

9. IDSE/Stage 2
Wholesale System
100,000
Wholesale and
Consecutive System
10,000
Consecutive System
50,000
Treatment
Plant
System A
System B
System C
LT2 R i v e r
Treatment
Plant
River
LT2
This is an illustration of a combined distribution system.
In this example, System A sells water to System B, which in turn sells water to System C. System A is the largest system in the combined distribution system. System B has its own source and sells water to System C.
For LT2 system A must comply on schedule 1 (>100K). System B serves 10k in its system and sells to system C which serves 50K population therefore, B must comply monitor its source water and implement treatment on Schedule 2 due to selling water to System C with >50K population.
For Stage 2 DBPR System A complies based on the requirements for a system serving 100,000 people. But because System B purchases water from System A, System B must comply with the Stage 2 DBPR schedule based on the population of the largest system in the combined distribution system, which is System A. Even though System C does not sell water and does not have its own source, it is still required to comply with the schedule of the largest system in the combined distribution system, which is System A.
Bottom line is smaller system sellling water to larger ones need to verify LT2 source testing requirements with state and smaller systems selling water to or buying water from larger systems need to verify their IDSE/Stage 2 schedules with States and /or EPA
Subpart H (SW or GWUDI) systems could end up on different schedules for LT2 source monitoring and IDSE/Stage 2 disinfection byproduct monitoring and treatment implementation

10.
IDSE/Stage 2 Distribution Disinfection Byproducts --General Requirements
Purpose of IDSEs:
Determine locations of high TTHM and HAA5 concentrations throughout distribution system
Results are used in conjunction with Stage 1 DBPR compliance monitoring to identify and select Stage 2 DBPR compliance monitoring locations (used for LRAA effective 2012 or later)
Every PWS must perform separate IDSE and Report
Stage 2 sampling may go back to combined system—minimum of 1 sample per system
To comply with Stage 2 DBPR IDSE Requirements, all CWSs and all NTNCWSs serving at least 10,000 persons that treat their water with a primary or residual disinfectant other than UV or deliver water that has been treated with a primary or residual disinfectant other than UV must qualify for a Very Small System (VSS) Waiver, apply for 40/30 Certification, conduct Standard Monitoring and develop a report, or conduct a System Specific Study and develop a report.

11. Stage 2 DBPR 1 2 3 4 Stage 1 continues IDSE Options VSS Waiver
40/30 Certification
Standard Monitoring
System Specific Study
Stage 1 continues
Existing &/or New Data May Apply
This illustrates the process systems will follow in implementing the Stage 2 DBPR.
VSS Waiver: PWS <500 POP, Has DBP data, State has not required IDSE
Nothing else required—no IDSE..proceed to Stage 2 according to deadlines
40/30 Certification: 8 consecutive quarters of THM and HAA data at Stage 1 sites with all individual data <40 THM /30HAA. Must submit Certification letter and data by 1st deadline.
If approved, no IDSE, proceed to Stage 2 according to deadline.
System Specific Study with prior data -- recent (prior) comparable data, 1.5 x SMP sample requirements, certified analysis, representative of system. Must submit SSS report for approval according to deadlines—If approved proceed to Stage 2 according to deadlines
SSS with Hydraulic Model & one round of SMP type data-- Computer model meets IDSE criteria,SMP equivalent samples collected once during peak month & support model predictions. Must submit report for approval. If approved proceed to Stage 2 according to deadlines
Choose Stage 2 TTHM/HAA5 Sites for Compliance
Conduct Stage 2 Compliance Monitoring
LRAA

12. Stage 2 DBPR 1 2 3 4 Stage 1 continues IDSE Options VSS WaiverNO
IDSE
Prior data
1.5 x SMP
IDSE Options
Model
0.2 x SMP 1 2 3 4
VSS
Waiver
40/30 Certification
Standard Monitoring
System Specific Study
Stage 1 continues
Existing &/or New Data May Apply
Many will do Standard Monitoring form of IDSE which will involve Disinfection Byproducts (Paired THM and HAA Samples throughout distribution system at specified/approved sites for 1 year – number sites and samples based on population.
Lots more samples (about twice the Stage 1 number) on schedules not in sync with ongoing Stage 1 testing
60 or 90 day intervals of testing will be required depending on system population
Sample schedules and site plans (with schematic) due Oct 1, 2006 for Schedule 1 systems & Consecutives
Stage 1 requirements continue through or later, depending on start schedule
IDSE will be basis for locating highest DBP Stage 2 sites, all of which must meet 80/60 LRAA MCLs in 2012
All these options to prepare for Stage 2 require at least some THM and HAA testing within each single public water supply.
How systems plan, conduct, document and use this testing will determine much of their success or failure in compliance with Stage 2 disinfection byproducts Rule
Choose Stage 2 TTHM/HAA5 Sites for Compliance
Conduct Stage 2 Compliance Monitoring
LRAA

13. TTHM and HAA5 Standard Monitoring(1)
For Subpart H systems and systems that purchase Subpart H water
Population
Frequency
Total
Near EP
ART
High TTHM
High HAA5
<500 consecutive
1 (during peak historical month)(2) 2 1 -
<500 non-consecutive
500-3,300 consecutive
4 (every 90 days)
500-3,300
non-consecutive
3,301-9,999 4
10,000-49,999
6 (every 60 days) 8 3
50, ,999 16 5
250, ,999 24 6
1,000,000-4,999,999 32 10
> 5,000,000 40 12
Standard Monitoring locations and frequencies depend on system size and source water type. This slide shows monitoring frequencies and locations for systems using surface water or GWUDI as a source. Systems must collect TTHM and HAA5 dual sample sets. In a CDS, a system’s Schedule is based on the largest system in its CDS; however, the number of samples a system must collect is based on the individual system’s population, not the largest system in the CDS.
EP = entry point
ART = average residence time
Footnotes
(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.
(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.

14. Challenges for Consecutive Systems
Receive water that has already been treated
May contain DBPs
May contain high levels of precursors and disinfectants
BATs for systems with their own source focus on
precursor removal
Not an option for consecutive systems
Stage 2 DBPR introduces new
BATs for consecutive systems
Management of distribution system and storage
Chloramination
Consecutives and wholesalers work together for best alternatives
Consecutive systems that are having problems meeting the MCLs for TTHM and HAA5 will face challenges that are different from those faced by non-consecutive systems. The BATs for systems that have their own sources (e.g., GAC, nanofiltration) are based on controlling DBPs through precursor removal. Consecutive systems do not control the treatment trains for the water they purchase. If the water they receive from wholesalers already contains DBPs or precursors and disinfectants that produce DBPs, the Stage 1 DBPR BATs will not address the problem for non-consecutive systems.
As a consequence, the Stage 2 DBPR includes:
Two BATs for large (> 10,000 people served) consecutive systems: chloramination and management of hydraulic flow and storage to minimize residence time in the distribution system. Chloramination has been used for residual disinfection for many years to minimize the formation of chlorination DBPs, including TTHM and HAA5.
One BAT for small (< 10,000 people served) consecutive systems: management of distribution system and storage to minimize water residence time in the distribution system. EPA has not included chloramination as a BAT for small systems because it requires operator supervision and adjustment. Many small systems lack treatment expertise and improper treatment can cause operational difficulties such as nitrification in the distribution system.
The BATs for consecutive systems do not focus on precursor removal. EPA still believes that precursor removal remains a highly effective strategy to reduce DBP formation, but recognizes that it is not applicable to consecutive systems. EPA believes that the best compliance strategy for consecutive systems is to collaborate with wholesalers to help achieve the water quality needed.

15. Challenges for Consecutive Systems
States have taken different approaches in past
May lack data to determine appropriate monitoring locations for Stage 2 DBPR
May not be eligible for VSS Waiver or 40/30 Certification under IDSE if lacking data
Would need to do Standard Monitoring or SSS
Work with wholesaler
May have taken samples in consecutive system’s distribution system
System-specific/state-specific regulatory interpretations may apply
Important Speaker’s Note: Tailor this discussion based on whether consecutive systems were required to comply with the Stage 1 DBPR. Consecutive systems might be in decent shape for the Stage 2 DBPR, or they may need a lot of assistance.
Because consecutive systems were not specifically addressed under the federal Stage 1 DBPR (although some states required compliance), many consecutive systems do not have data on locations of high TTHM and HAA5 concentrations and may not be able to determine appropriate monitoring locations for their IDSE. They also may not be eligible for some of the IDSE waivers.
Consecutive systems are encouraged to contact their wholesale provider as soon as reasonably possible after promulgation of the Stage 2 DBPR to determine what plans, if any, the wholesale system has already made regarding the IDSE.
Although each system will have to develop a schedule and plan that is specific to their system, coordinating IDSE monitoring schedules will allow the two (or more) systems to better utilize data from the IDSE monitoring period to formulate a Stage 2 DBPR compliance strategy, if necessary. At a minimum, coordinating the IDSE monitoring schedules helps the wholesale and consecutive system(s) better understand DBP formation across the combined distribution system. Consecutive systems also may want to check with their wholesale system to determine if the wholesaler has conducted monitoring in the consecutive system’s distribution system. If this is the case, the consecutive systems may be able to use this information.

16. Tennessee Regulatory Overview & Case Study Examples

17. Tennessee Stage 1 Regulations & Case Study Examples
Consecutives in combined systems have been included in compliance DBP monitoring and calculations since 1999
All systems required to test since except where small systems are surrounded by larger systems (ex. apartment systems)
<500 population systems are encouraged to monitor this summer to qualify for VSS waiver.
No chloramines allowed in Tennessee to date.
Many systems are in compliance using optimized treatment with alternate in-plant pre-filter disinfection (H2O2, enhanced coagulation, P-carbon, G-carbon)
Some large systems will qualify for 40/30 certification
TDEC
TDEC

18. Tennessee on the New Regs
TDEC Contact:
Most TN ground water systems and even some large subpart H systems will qualify for the 40/30 certification. (One TN field office was already issuing 40/30 certifications in April 06.)
Systems need to be aware that IDSE System Specific Studies (Modeling or prior DBP data) will be reviewed by the EPA and not the states.
Tennessee will expect combined distribution systems to coordinate sampling, so that, for the most part, everyone samples on the same days in order to make the data comparable.
Systems encouraged to work closely with the state laboratory certification officers to minimize errors inherent to method used for haloacetic acids. See the August 18, table V-19 Federal Register proposals for details. Surrogate recoveries and other factors need to be looked at in regard to lab results.

19. Tennessee on the New Regs
TDEC Contact:
Systems need to be aware that they should sample early in the compliance period, and insist on analytical results as soon as possible, so that the system can collect additional samples to address abnormally high, or questionable, analytical results before compliance period ends.
Systems need to be aware that Stage 2 Rules revise the Stage 1 Rules to require TOC sampling at plants using non-conventional filtration to qualify for reduced monitoring.

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

21. Nontraditional water systems
Nashville Water Department
West Wilson W.D.
Brentwood Water Dept.
“Non-Traditional Water Systems”
-Property Owners
-MHP
Total in CDS: 62
This is only an example of why we need systems to work together.
Our biggest difficulty at an EPA Region when we conduct the early implementation is providing compliance assistance to what I like to call “nontraditional” water systems. These are water systems whose primary line of business is to sell something or provide a service that has nothing to do with water. That would mean that this group will not be members of AMWA, AWWA or NRWA. The only channel of communication the Agency can rely on is written correspondence, which is easily discarded.
The example I’m showing you is in Nashville/Davidson County, Tennessee. This is a common pattern not only in large metropolitan areas, but in the smallest towns where a wholesale source of water is selling to some mobile home parks on the edge of town. It also happens to county water authorities.
An EPA Region needs your help, because we lack the local knowledge and the resources to acquire it. The wholesaler is the communications key in the combined distribution system…
Source: SDWIS and TN DWS, (compiled by R-IV EPA)

22. One County – 89 pubic water supplies
Safe Drinking Water Query Form for the State of Tennessee
Query Form
Search the SDWIS Database \
Query Form
Search the SDWIS Database
One County – 89 pubic water supplies

23. 4 water providers; 85 purchasers

24. 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

25. 34 systems <500 population may qualify for VSS Waiver with DBP results

26. Knoxville Utilities Water System
Large wholesaling SW System (population 190,324)
Low TOC source (Tennessee River)
Bin 1 Crypto—with “grandfather-able” data
Conventional clarification treatment, chlorine dioxide/free chlorine
One consecutive with multiple wholesalers
Other wholesalers have 40/30 Certifications
All assigned to same Schedule 1 CDS

27. W3
(JC) W2
(NM)
KUB W1
CS1
(SG)
CS2
(DD) W3
(SV) W4
(NP)

28. Knoxville DBP history -> LT2/Stage 2 IDSE
Free chlorinated system—close to 40/30
Max month September – DBPs sampled in special studies
Using fluoride tracers to measure retention time & select SMP IDSE sites
automatically monitored – fluoride probes configured with data loggers
time for non-fluoride treated water to reach points in system to track water retention time
Studies to extend into consecutive system

29. Summary of KUB Fluoride Tracer Studies -- Setup & Results
Six probes and data loggers
Four separate testing events to-date
North, South, East & West system areas
Sites selected from hydraulic model and general system knowledge
Track time for fluoride level changes
drop after shutting off fluoride at plant
return after turning back on at plant
Very Interesting findings– an excellent tool.
Making distribution operational changes based on test findings
Additional studies planned
Repeat all tracer tests (as time allows prior to IDSE plan deadline)
Longer holding-time SDS for comparison

30. Kentucky Regulations & Case Study Examples

31. Kentucky Regulations & Case Study Examples
Consecutives in combined systems have been included in Stage 1 compliance monitoring and compliance tabulations of the combined systems (wholesaler and purchaser) since 1990.
Pre-chlorination has been required for most part
Few chloraminating systems (larger, some seasonal)
State guidance for moving point of chlorination and for conversion to chloramines

32. Combined Consecutive Systems have “joint” responsibility for DBP formation and control (under current KY regs)
Buyer, purchaser, Consecutive
Seller, producer, Wholesaler
THM/HAA compliance = average of four sites per “joint” (or combined) system

33. Consecutive B(<10K): purchased & rechlorinated
Wholesaler C (>10K): GW & free chlorine Wholesaler D (<10K): GW & free chlorine
Consecutive B(<10K): purchased & rechlorinated
Wholesaler A(<10K): SW free chlorine or chloramine seasonal, variable
Wholesaler F(>50K <100K) SW & chloramines; yearly brief free chlorination
Wholesaler G(>100) SW & chloramines) yearly brief free chlorination. Breakpoint free chlorinated as Consec B’s master meter for nitrification control.
Wholesaler E (>10K,<50K) SW & chloramines, no yearly free chlorination; water may be purchased from supplier F or G.

34. Some systems are already meeting LRAAs (ground water and chloraminating systems) and others have a way to go.
Intermittent supply connections
<50K
>50K
>100K
Chloramines
Free chlorine

35. Even large (>300K) system (including multiple consecutives) in compliance using pre-filter Chorine, optimized coagulation and distribution Chloramines
Average Yearly THM & HAA Levels
0.02
0.04
0.06
0.08
0.1
0.12
0.14
0.16
1980
1984
1988
1992
1996
2000
THMs/HAAs (mg/l)
Ferric Chloride
Lowered/Raised
Coagulation pH
Alum at high pH
Ferric PACL
Pre-Chlorine dioxide Intermediate chlorination
Partnership Turbidity Optimization
Chloramines
EVEN LRAAs
Distribution Free Chlorine
Chloramines
2004
Increased # max sample points
Decreased # max sample points

36. Free Chlorinated System DBPS
Wholesaling systems need to be optimized according to Stage 1 requirements and guidance –prior to chloramine conversion
State approvals, benchmarking required prior to change impacting treatment CT
Distribution retention time must be managed
Go to the max site LRAA if you want to know what the future holds
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

37. Continuous, relatively small volume connections
START DATE FOR MONITORING AND COMPLIANCE—DETERMINED BY LARGEST POPULATION SYSTEM IN A COMBINED SYSTEM.
States may use knowledge of system to decide whether a smaller system is considered consecutive of the larger for this purpose of IDSE/S2 scheduling .
Intermittent supply connections
<50K
>50K
>100K

38. How many samples…when?
24 Systems: (>100Klargest): IDSE > 54 Stage ISDE site plans due months after promulgation
Where the consecutive system lines are drawn has huge implication for smaller systems’ compliance, lab
workloads and sample coordination by multiple utilities.
<50K
>50K
>100K
<50K

39. For iIlustration purposes only-- All CDS assignments must be verified by KYDOW
CDS Schedule 2 (<100K >50K)
CDS Schedule 4 (<10K SW &GW)
CDS Schedule 34 (<10K SW &GW)
<50K
>50K
>100K
<50K
CDS : (>100K largest)

40. <50K >50K >100K >100K <50K <50K
For iIlustration purposes only-- All CDS assignments must be verified by KYDOW
CDS Schedule 4 (<10K SW &GW)
CDS Schedule 2 (<100K >50K)
CDS Schedule 1: (>100K largest)
CDS Schedule 3 (<10K SW &GW)
<50K
>50K
>100K
>100K
<50K
<50K
<50K
CDS Schedule 1: (>100K largest)
CDS Schedule 3 (<10K SW &GW)

41. IDSE Standard Monitoring Plan – Case Study Louisville Water Company & Consecutives
LWC Large Wholesaling (Population 349,000)
Surface Water Source (Ohio River, Moderate TOC)
Two WTPs conventional treatment plus RBI
Chlorine,Chloramines
Multiple Consecutive Systems with multiple wholesalers
4 separate PWS assigned to LWC CDS
Consecs included in Stage 1 DBP compliance
Contract lab for TTHM & HAA5 testing
LWC conducting IDSEs for consecutives
Coordinated w/LWC IDSE/Stage 2 on Schedule 1

42. LWC W1
CS5
CS1
CS4
CS2
CS3 W4 W3 W6 W2 W5

43. LWC W1
CS1
CS4
CS2
CS3 W3 W2

44. IDSE Plans
Plan must be submitted according by October 1 for Schedule 1 systems to include (Use Forms from IDSE Guidance Manuals-filled in examples are included)
System ID & descriptions
Description of processes to select sites, data summaries used
Sites IDs with justifications—assess available data & sites in context of known hydraulics
Peak Historical Month Basis
Schedule including sampling during max historical month
Schematic – sources, entry points, storage facilities, pressure zones, pumps locations, SMP and Stage 1 Sites (map or schematic scale, minimize use of known landmarks for security)
May review larger, complex systems with State prior to submittal

45. Finding Maximum DBP Month
Highest historical =
3rd Quarter (July)
May be selected based on historically highest THMs or HAA5s or water temperature

46. Finding Maximum DBP Month
Highest historical DBP =
3rd Quarter (July), Highest temperature = Aug
May be selected based on historically highest THMs or HAA5s or water temperature
Other factors may come into play as well… TOC, pH, hydraulics or treatment changes

47. Stage 1 & IDSE Scheduling
Pop
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Total
LWC Wholesaler
836,925
Stage 1 18 72
IDSE SM 24
144
Consec 1
4,290 1 4 20
Consec 2
15,717 8 48
Consec 3
12,823
Consec 4
12,500 22 40 62 44
332

48. Stage 1 & IDSE Scheduling
Pop
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Total
LWC Wholesaler
836,925
Stage 1 17 68
IDSE SM 24
144
Consec 1
4,290 1 4 20
Consec 2
15,717 8 48
Consec 3
12,823
Consec 4
12,500 22 40 62 44
332

49. Stage 1 & IDSE Scheduling
Pop
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Total
LWC Wholesaler
836,925
Stage 1 16 64
IDSE SM 24
144
Consec 1
4,290 1 4 20
Consec 2
15,717 8 48
Consec 3
12,823
Consec 4
12,500 22 40 62 44
332

50. Stage 1 & IDSE Scheduling
Pop
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Total
LWC Wholesaler
836,925
Stage 1 15 60
IDSE SM 24
144
Consec 1
4,290 1 4 20
Consec 2
15,717 8 48
Consec 3
12,823
Consec 4
12,500 22 40 62 44
332

51. Stage 1 & IDSE Scheduling
Pop
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Total
LWC Wholesaler
836,925
Stage 1 14 56
IDSE SM 24
144
Consec 1
4,290 1 4 20
Consec 2
15,717 8 48
Consec 3
12,823
Consec 4
12,500 22 70 52
380

52. Analyzing DBP Formation Factors and projecting Stage 2 compliance
Keep track of LRAA at each site
Re-analyze historical data for DBP FP insights
Generally, chloraminating systems will experience very little DBPs increases with retention time, HAA5s may decrease

53. Coordinating IDSE Stage 2 Monitoring and Compliance Efforts in Combined Systems
Meetings to train and plan
Each PWS must conduct separate IDSE and submit plans and reports separately
States may allow Combined System DBP sampling for Stage 2 (2012 or later)
All individual sites will have to meet LRAA at Stage 2 sites
Large volume lab economies
Tracking and Reporting efficiencies
Better water operations understanding and choices and compliance potential in the long term
IDSE/Stage 2 sites
Where is the oldest water… maps, chlorine residuals.. historic DBP sites & sample results,
Representative

54. Confounding Issues for all systems
Under Stage 2 Maximum LRAA sites may need to move due to system changes.
How do we calculate LRAA compliance that is:
truly reflective of the water served to a given service area and
still hold systems accountable for minimizing DBPs at a highest max site?
IDSE is a snapshot--make best choices to find maximums -- realizing highest LRAA sites/month may/will end up compliance sites/month under Stage 2

55. Zone for potential variable supply if chlorine same
Free Chlorine
Groundwater
Very low TOC & DBPFP
Higher hardness, Fe, Mn
Free Chlorine
Limited Surface Water
Higher TOC & DBPFP
Chloramines
Surface Water
Lower TOC & DBPFP
Nitrification
Booster Chlorine to Free Chlorinate

56. ? ? New Stage 2 Sample site plan.....
IDSE = “Research
Project” – lots of sites sampled to find Stage 2 sites for future LRAA compliance ?
New Stage 2 Sample site plan.....
based on IDSE..will have to live with it
or justify changes. ?

57. IDSE Sample Site Plans, VSS waiver or 40/30 certification for Schedule 1 Systems Due October 1, 2006!!
SEE EPA WEBSITE FOR GUIDANCE MANUALS/FORMS, REGS, TRAINING

58. Using Guidance Manual Examples to Understand IDSE Report & Stage 2 Site Selection
Follow Guidance manual instructions to review data and select Proposed Stage 2 sites
Use FORM 7 “IDSE Report for Standard Monitoring”

59. 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 mg/L, system is in compliance
Sort data from highest to lowest HAA5 LRAA—(separate spreadsheet)
For each site, sum of results for each sample period and divide by number of sample periods for one year = LRAA
If LRAA HAA5 results are under mg/L, system is in compliance

60. 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.

61. 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 mg/L, system is in compliance
Sort data from highest to lowest HAA5 LRAA—(separate spreadsheet)
For each site, sum of results for each sample period and divide by number of sample periods for one year = LRAA
If LRAA HAA5 results are under mg/L, system is in compliance

62. Use EPA sequence described in Regulation CFR 141
Use EPA sequence described in Regulation CFR and IDSE Guidance Manual to select Stage 2 sites
Report 3 months after IDSE completed—January 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.

63. IPMC Primacy Agencies Regional MDBP Team EPA HQ EI Team
HQ SSS Review Team
IPMC
Primacy Agencies
Regional MDBP Team
EPA HQ EI Team
Wholesale PWS
Consecutive PWS
Reporting and Tracking Using Multiple People and Methods for Early Implementation

64. Effective source selection and use.
Optimized DBP precursor removal, chlorine/chloramine applications
Effective distribution operations, sampling and flushing programs, tank turnover more important than ever.
Extended low flow rural/residential areas may need blow offs and/or sampling hydrants to provide sample sites and to ensure routine water 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.

65. Take home messages Learn/Know your systems—work together across
Plan IDSE sampling in cooperation with State (EPA), wholesale and consecutive systems, working together—look at the big picture and exercise best discretionary options.
Apply for VSS Waiver, 40/30 Certification if applicable
Submit IDSE Plans as required
Don’t overlook the obvious (Find and FIX THE HOT SPOTs--so they don’t end up as max LRAA sites!)
Consider future changes--supply, facilities’ configuration, operations– how will they impact DBPs and/or disinfection..or corrosion control??
Line up a dependable labs and keep close track of samples and trends
Complete capital changes in time to meet Stage 2 LRAA MCLs
If change is to chloramines; minimize water age, implement a nitrification control plan up front.
Remember any disinfection change must be carried out with extreme caution…and State approval.
Remember CCR reporting requirements

66. Acknowledgements Louisville Water Company & Consecutives
Knoxville Utilities Board
Kentucky American Water
Tennessee Division of Water Supply
Kentucky Division of Water
EPA HQ & Region IV EPA
Further Information Contact:
Jan Routt & Associates, LLC
(859)
website: