1. Ohio EPA Update Holly Kaloz Manager, Compliance Assurance Section Division of Drinking and Ground Waters April 24, 2014 Ohio Section AWWA SE District Spring Meeting

2. Revised Total Coliform Rule (RTCR) Save a Dime, Sample on Time! Lab Oversight Updates Lead Free Updates Legionella Treatment Electronic Reporting Backflow Rules Updates Operator Certification Harmful Algal Blooms (HABs) Water Supply Revolving Loan Account (WSRLA) Overview

3. USEPA Rule issued as Final Ohio rules adopted Ohio rules out for public comment Ohio rules effective RTCR Background

4. Applies to ALL public water systems (PWS) MCL for total coliform eliminated New MCL for E. coli Treatment Technique (Find and Fix Approach) Level 1 or Level 2 Assessments RTCR Big Picture

5. Large Community PWS  Routine monitoring is unchanged Small Community PWS (pop <1001)  One sample per month  Ohio EPA does not plan to adopt Fed provision for quarterly sampling RTCR Basics - Routine Monitoring

6. Small Noncommunity PWS (pop <1001) Affected most by new rule Baseline will remain 1 sample per quarter Ohio EPA does not plan to adopt reduced annual monitoring In the month following TC+: 3 instead of 5 Triggered monthly monitoring 2 or more TC monitoring violations w/in past 12 months Combination of one Level 1 Assess. and one TC mon. viol. Level 2 Assessment Treatment technique violation RTCR Basics - Routine Monitoring

7. Seasonal Systems – By definition a PWS that serves water a portion of the year and shuts-down Start-up procedure and report TC sample 1x/month during season will be proposed as baseline RTCR Basics - Routine Monitoring

8. 3 instead of 4 Additional sets of repeats E. coli is sole fecal indicator Failure to take all is not a monitoring violation  Triggers a Level 1 Assessment Consecutive GW Systems must notify supplier RTCR Basics - Repeat Monitoring

9. Triggers  > 5.0% TC+ for PWS taking 40 or more samples/mo  2 or more TC+ for PWS taking <40 samples/mo  Failure to take all repeat samples Goal – ID problems w/ sampling and cause of TC+ Requirements  By PWS – Ohio intends to assist by phone  Required elements – emphasis on sampling protocol and distribution system upsets  30 day turnaround  Failure to complete is TT violation RTCR Basics - Level 1 Assessments 9

10. Triggers  An E. coli MCL, or  A second L1 Assess within 12 months Goal – ID sanitary defects and cause of EC+ Requirements  By a state approved person – Ohio EPA expects to do them  Required elements – same as L1 but more detailed  30 day turnaround  Failure to complete is TT violation RTCR Basics - Level 2 Assessments 10

11. E. coli MCL violation – Tier 1 PN Treatment technique violations – Tier 2 PN Monitoring violations Reporting violations RTCR Basics - Violations ROUTINEREPEAT EC+TC+ EC+Any missing sample TC+EC+ TC+TC+ - but no E. coli analysis

12. Monitoring violations - only 2  Failure to take routine total coliform sample  Failure to analyze for E. coli following a TC+ routine sample Reporting violations - new ones  Failing to submit an Assessment form on time  Failure by a seasonal PWS to submit documentation that required start-up procedure was completed RTCR Basics - Violations

13. Save a Dime, Sample on Time! New Ohio EPA program to provide a deterrent to violations and increase public health protection. More expensive to fail to sample than it is to sample. Beginning January 1, 2014, there will be a penalty of $150 or more for each monitoring violations. (NOVs after 1 st qtr) Don’t put your consumers at risk, sample on time!

14. Lab Oversight Update Assessing reporting compliance for laboratories Began issuing routine Notices of Violation to laboratories for reporting violations in 3 rd quarter 2013 – Significant decrease in the number of late sample reports May result in further enforcement

15. Lead Free Requirement U.S. EPA has posted a revised list of FAQs at: http://water.epa.gov/drink/info/lead/upload/epa815 s13001.pdf http://water.epa.gov/drink/info/lead/upload/epa815 s13001.pdf Repairs have been clarified Hydrants exempted from coverage Still some problematic language Pb/Cu Long Term Revisions – NDWAC advising USEPA

16. Legionella Treatment Increasing outbreaks Hospitals seeking additional treatment Makes them a regulated PWS Treatments – Copper Silver Ionization – Chlorine Dioxide Operational/Distribution Requirements Statewide group working on guidance for healthcare facilities

17. Electronic Reporting Requirement to submit monthly operational report (MOR) to Ohio EPA using eDWR by the following dates: Population Served Latest Date to Begin 3,301 or more July 1, 2012 501 - 3,300 July 1, 2013 500 or fewer July 1, 2014 Contact Brian Tarver with questions (614) 644-2752

18. Backflow Rules Working on addressing Commerce’s recent comments Sub-group formed for unresolved items – Ohio EPA – PWS – ORWA and OAWWA – Commerce Manual is being revised to address comments Reopen booster pump rule to address conflicts

19. Rule Making – Coming Soon Class 1 ORC provision Allow individual that passes Class I water supply exam but does not meet experience requirements to be the ORC if specific conditions are met Clarify classification of systems satellite/consecutive systems TNC < 250 with 4-log disinfection or nitrate removal treatment Operator Certification

20. Class I Water Supply Training Fill in forms Opcert list serve Eapps is coming eventually Approved exam provider in place Operator Certification

21. Approved Exam Provider Association of Boards of Certification (ABC) – 5 locations – 3 hour test – 100 questions

22. Two Pathways for Certification using ABC Testing Ohio EPA Testing Service – Application (attestation) – Immediate registration – EPA equivalent exam – 30 day retake waiting period – Full fees required for a retake Certification using ABC Testing

23. Approved Exam Provider Fees Ohio EPA Testing Service – Exam Fee $47 – Exam administration fee $64 – Total $111

24. How does an operator get Ohio EPA certified via ABC Exam? 1.Pass ABC Exam 2.Apply to Ohio EPA – $45 Fee – Document experience (OITs should wait to apply until they meet experience requirements) 3.Ohio EPA Issues Certificate OR - Paper and pencil tests will still be offered 2 times per year at the Ohio Expo Center

25. Eapplication and Epayment E-application – Ebiz center Exam applications Renewal applications Contact hour applications Epayment

26. Operational Records OAC 3745-7-09 – “Accurate and Authentic” – Maintained onsite available for 24 hour inspection – At a minimum, the following information shall be recorded: (a) Identification of the public water system, sewerage system, or treatment works; (b) Date and times of arrival and departure for the operator of record and any other operator required by this chapter ;

27. Operational Records (c) Specific operation and maintenance activities that affect or have the potential to affect the quality or quantity of sewage or water conveyed, effluent or water produced; (d) Results of tests performed and samples taken, unless documented on a laboratory sheet; (e) Performance of preventative maintenance and repairs or requests for repair of the equipment that affect or have the potential to affect the quality or quantity of sewage or water conveyed, effluent or water produced; and (f) Identification of the persons making entries.

28. Harmful Algal Blooms (HABs) HAB Monitoring Summary – Ohio EPA collected 1268 raw and finished water cyanotoxin samples at 40 water systems – PWS have submitted results for over 600 raw and finished water cyanotoxin samples (7 systems) – Cyanotoxins have been detected in the majority of the source waters sampled in Ohio – Three finished water microcystin detections (>0.25ug/L), one above drinking water threshold (1.0 ug/L) – First drinking water advisory issued in 2013

29. Ohio Harmful Algal Blooms (HABs) 2010 - 2013 Recreation Use Advisories Water Systems with HABs in Source Water

30. Welston- Lake Alma 2010 Lima 2011 Findlay 2012 Bur Oak 2010 Clermont CO- Harsha Lake 2012 Examples of Harmful Algal Bloom on Ohio’s Inland Public Water Supply Lakes and Reservoirs Wilmington -Caesar Creek Lake 2011 Bowling Green 2013 Akron- Lake Rockwell 2011

31. Example of Source Water With High Toxin Concentration (>100 ug/L microcystin)

32. Harmful Algal Blooms (HABs) Preparing for 2014 HAB Season – Meetings with USEPA, NOAA, CDC and others to share information – Prioritize funding for HAB-related treatment Added points to WSLRA ranking system – Algae Questionnaire coming soon Webinars scheduled for April 29 and 30 – Updating HAB Strategy

33. $193.3M requested loans for upcoming project year – 79 water systems for 119 projects – Range from $5,000 to $24M per project, average $1M per project – All projects should get funded Considering offering targeted funding for emergency power in future Water Supply Revolving Loan Account (WSRLA)

34. Questions? Holly Kaloz Ohio EPA, DDAGW 50 W. Town St., Suite 700 Columbus, Ohio 43215 614-644-2752 holly.kaloz@epa.ohio.gov