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Long Term 2 Enhanced Surface Water Treatment Rule – LT2

Mark McIntire

Drinking Water Program

SDWWA Water Seminar

February 7, 2006

Please ask questions as we go along

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Surface Water Treatment Rule Review

Source for many large systems in SD.

Especially vulnerable to microbial contamination

Crypto, E. coli, and Giardia lamblia present in most surface waters

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Disinfection & FiltrationDisinfection

Essential part of water treatment

Creates DBPs Crypto resists traditional

disinfectants

Filtration Most surface water systems filter Key barrier against microbial

contamination Physical process can remove Crypto Disinfection still necessary

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Understanding “log” removal Refers to percent of Crypto that is removed or

inactivated by treatment or other measures

Log % removal/inactivation

0.5-log 68.4%

1-log 90%

2-log 99%

3-log 99.9%

4-log 99.99%

5-log 99.999%

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“Log” Removal Example 1System B

Both systems provide the same level of Crypto removal/inactivation, but System B provides higher quality finished

water

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ater 1 Crypto oocyst

2-log removal/ inactivation (99%)

1 Crypto oocyst

System A

100,000 Crypto oocysts 100 Crypto oocysts

2-log removal/ inactivation (99%)

1,000 Crypto oocysts

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“Log” Removal Example 2

5-log removal/ inactivation (99.999%)

System B

Both systems provide the same public health protection, but System A must work harder!

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ater 1 Crypto oocyst

2-log removal/ inactivation (99%)

1 Crypto oocyst

System A

100,000 Crypto oocysts 100 Crypto oocysts

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“Log” Removal Example 3System B

System A and B have the same source water Crypto level but System A provides a greater level of removal/inactivation, resulting

in higher quality finished water!

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10 Crypto oocysts

2-log removal/ inactivation (99%)

1 Crypto oocyst

System A

1,000 Crypto oocysts 1,000 Crypto oocysts

3-log removal/ inactivation (99.9%)

1 Crypto oocyst

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M-DBP History LT2ESWTR (2006)

Improves microbial protectionBuilds on SWTR, IESWTR, & LT1ESWTRDoes not change any existing requirements

from SWTR suiteFlexible, risk-based rule based on new Crypto

data The amount of Crypto detected in the source water

determines the additional levels of required treatment

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SWTRs Summary• All Subpart H systems

• Reduce risks from Giardia lamblia & viruses

SWTR (1989)

• Subpart H systems serving > 10,000• Address Crypto with improved treatment

IESWTR (1998)

• Requirements similar to IESWTR applied to Subpart H systems serving < 10,000

LT1ESWTR (2002)

• All Subpart H systems• Target additional treatment at highest-risk

systems

LT2ESWTR (2005)

Questions? NEXT

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Purposes of the LT2ESWTR Improve public health protection

Reduce illness caused by Crypto and other microorganisms

Tailor requirements based on: Level of treatment Source water quality System size

Provide systems and states with flexibility

Most systems will only need to monitor

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Applicability All Subpart H systems

Use surface water or GWUDI sourcesCWSs, NTNCWSs, TNCWSsWholesale systems

Compliance deadlines and options based on number of people servedDivided into four schedulesWholesale systems with own Subpart H

source(s) comply based on population of largest system in their CDS

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SchedulesIf you have a Subpart H source and are this kind of system:

You are on

Schedule number:

System serving 100,000 or more people OR a wholesale system in a CDS that contains a system serving >100,000

1

System serving 50,000 to 99,999 people OR a wholesale system in a CDS that contains a system serving 50,000 to 99,999

2

System serving 10,000 to 49,999 people OR a wholesale system in a CDS that contains a system serving 10,000 to 49,999

3

System serving fewer than 10,000 and not a wholesale system

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LT2ESWTR Process

Initial Round Source Water Monitoring

Bin Classification

Choose Toolbox Option(s)

Implement Tool(s)

Second Round Source Water Monitoring

Bin 1 systems

Small systems w/ low E. coli

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1

3

4

5

Systems installing

max treatment

Systems Subject to LT20

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Requirements based on: System size Wholesale status Source water Operating calendar

Initial round Start date based on system size For wholesale systems, based on largest

system in CDS Grandfathering is permitted

Source Water Monitoring1

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Filtered PWSs are classified into one of four binsBased on initial monitoring results

May set additional requirementsBin 1: no additional treatmentBins 2, 3, 4: additional treatment or control

processes Covered in future trainings

Bin & Treatment Overview2

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Range of treatment and control process options to meet bin requirements: Source protection and management Prefiltration Treatment performance Additional filtration Inactivation*

Offer Crypto treatment credits Options discussed in depth at future trainings

* Unfiltered systems are limited to these tools

Toolbox Options3

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Implement Option(s) Install chosen treatment to meet bin

requirements: Schedule 1 – April 1, 2012 Schedule 2 – October 1, 2012 Schedule 3 – October 1, 2013 Schedule 4 – October 1, 2014

State can allow up to 2 additional years Covered in future trainings

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Subsequent source water monitoring6 years after initial bin classification (filtered

systems)Same requirements apply

Can lead to bin reclassification Covered in future trainings

Follow-Up Monitoring5

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Implementation Timeline

1

201820172016 20192015201420132012201120102009200820072006

Treatment installation

Possible extension

Crypto monitoring

Crypto monitoring

Schedule 1

2

201820172016 20192015201420132012201120102009200820072006

Crypto monitoring

Treatment installation

Crypto Monitoring

Possible extension

Schedule 2

201820172016 20192015201420132012201120102009200820072006

Treatment installation

Crypto monitoring

Possible extension

Crypto Monitoring3

Schedule 3

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201820172016 201920152014201320122011201020092008

Implementation Timeline

201820172016 201920152014201320122011201020092008

4 Crypto

CryptoMonitoring

Treatment installation

Possible extension

E. coli

E. coli

4 E. coli

E. coli

Crypto

Treatment installation

Crypto

E. coli4 Possible extension

E. coli

Schedule 4

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Profiling and Benchmarking

Balance risks between microbial pathogens and DBPs

Impact of Stage 2 DBPR and Crypto requirements

Required when altering disinfection Develop profile for Giardia lamblia and

viruses Calculate benchmark

Requirements go into effect upon completion of initial monitoring

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Source Water Sampling

Source Water Monitoring For systems using surface water and serving 10,000

people or more Must monitor for Crypto, E. Coli and turbidity once a month for

24 months Seasonal systems must collect at least 6 samples evenly spaced

through months of operation

Systems using surface water and serving less than 10,000 people (Schedule 4 system) must monitor for E. coli once every 2 weeks for 12 months,

However (next slide)

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Source Water Sampling (cont.)

Systems less than 10,000 people using lake or reservoir sources If the annual mean E. coli concentration is greater than

10 E. coli per 100 mL, the system must collect 24 Crypto samples in either one or two years

Systems less than 10,000 people using flowing stream sources If the annual mean E. coli concentration is greater than

50 E. coli per 100 mL, the system must collect 24 Crypto samples in either one or two years

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Source Water Sampling Schedules

System

Population

Submit Sampling Schedule &

Location

Begin

Monitoring

> 100,000 July 1, 2006 Oct. 1, 2006

50,000 to 99,999 Jan. 1, 2007 April 1, 2007

10,000 to 49,999 Jan. 1, 2008 April 1, 2008

< 10,000 July 1, 2008 Oct. 1, 2008

Systems must submit to State or CDX a sampling schedule that specifies the calendar dates when the system will collect each required sample, 3 months prior to start of sampling

Systems must collect the samples within two days before or two days after the dates indicated in their sampling schedule

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Source Water Sampling Locations

Where do I collect my sample? Systems must submit a description of their sampling

location to the State or DCTS at the same time as the sampling schedule is required to be submitted.

Systems must collect source water samples (crypto, E. Coli and turbidity) prior to any chemical treatment.

Systems that recycle filter backwash water must collect source samples prior to the point of filter backwash addition.

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Sampling Before Chemical Treatment & Filter Backwash Recycle

Sample point

Filter backwash recycle(if applicable)

Treatment plant

Source water

Chemicaladdition

Filter backwash recycle(if applicable)

Raw water intake

Raw water chemical building

Sample point 1

Note: Sample point 1 is BEFORE

introduction of recycle

Sample point 2

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Approved Laboratories

Crypto and E. Coli sample analysis must be performed at EPA approved laboratories

Crypto samples must be sent to a lab from the list found on this EPA Website

http://www.epa.gov/ogwdw/disinfection/lt2/lab_aprvlabs.html E. Coli samples for this monitoring must be counts (enumeration),

not just presence/absence like routine monthly sampling Most labs in SD should be able to do this, but ask them first Also make sure that when you submit samples, the lab sheets indicate

that you want E. Coli counts not P/A

Turbidity – the system is allowed to take their own turbidity. Make sure your turbidimeter has been calibrated according to

manufacturers specifications.

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Reporting Results Systems must report results from source water monitoring

no later than 10 days after the end of the first month following the month when the sample is collected

EPA should be contacting all systems with a letter telling you how to access the CDX system.

Systems serving at least 10,000 people must submit the results electronically through EPA’s CDX system. Hopefully the labs will be able to submit the results for you. Make sure you fill out the lab sheets completely.

Systems serving less than 10,000 will be allowed to submit their source water data directly to the state. However, if the system registers in the CDX system, they may be able to get the labs to submit their results for them.

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Reporting Results (cont.)

What am I required to report?

For Crytpo Analysis1. PWS ID#

2. Facility ID #

3. Sample Collection Date

4. Sample Type (field or matrix spike)

5. Sample Volume Filtered (L)

6. Was 100% of filtered volume examined (yes/no)

7. Number of oocysts counted

For E. Coli Analysis1. PWS ID#

2. Facility ID #

3. Sample Collection Date

4. Analytical method #

5. Method Type

6. Source Type

7. E. Coli/100 mL

8. Turbidity (only for systems greater than 10,000)

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Questions????

• Drinking Water Program

773-3754• Drinking Water Program website:

• http://www.state.sd.us/denr/dw

• EPA website:• http://www.epa.gov/OGWDW/