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1

If you do not have a copy of the SWTRs handouts, a copy can be downloaded from the Encounter Collaborative meeting page:https://ei.e2c.com/enc/enc-pc.pmtg

2

Encounter Customer Care

General Technical Support at Encounter

800-290-5900, Option 1

Or press *0 on your telephone when dialed into your Express, Priority, or Broadcast Number to be transferred directly to Customer Care.

How many people are attending at your location? 1 Person 2 - 4 People 5 - 10 People 10 - 20 People More than 20 People

4

Evaluation Form – Available on the web at:

• http://yosemite.epa.gov/ogwdw/ogwdwsurvey.nsf/surveyhome?openform

• Enter code: survey07 Please email webcastinfo@cadmusgroup.com if

you have questions

New

5

Happy Sweet Sixteen!!!!!!!!

June 29, 1989 June 29, 2005

6

Surface Water Treatment Rules (SWTRs)

U.S. EPA

Webcast Training Session

June 29, 2005

2:00-4:00pm EST

7

SWTRs

SWTRs Training encompasses requirements of the following regulations:

• Surface Water Treatment Rule (SWTR)

• Interim Enhanced Surface Water Treatment Rule (IESWTR)

• Long Term Enhanced 1 Surface Water Treatment Rule (LT1ESWTR)

• Filter Backwash Recycling Rule (FBRR)

8

SWTRs Size Filtration Type SWTR

1989

IESWTR

1998

LT1

2002

FBRR

2001

Serving at least 10,000

Conventional or Direct Filtration

Slow Sand, Diatomaceous Earth or Alternative Filtration

Unfiltered Systems

Serving fewer than 10,000

Conventional or Direct Filtration

Slow Sand, Diatomaceous Earth or Alternative Filtration

Unfiltered Systems

9

SWTRs Purpose

Purpose: To improve public health protection through the control of microbial contaminants, including requirements for removal and/or inactivation of:

• Viruses

• Giardia Lamblia

• Cryptosporidium

10

SWTRs Scope

Scope:

• Applies to all public water systems using surface water or ground water under the direct influence of surface water (GWUDI), otherwise known as “Subpart H systems.”

Require all Subpart H systems to:• Disinfect

• Filter

• Individual filter monitoring & establishes CFE limits

• Apply treatment technique requirements for control of microbials.

Exception – Systems meeting Filter Avoidance Criteria only need to disinfect

11

Outline History of Microbials Overview of SWTR, IESWTR, and LT1ESWTR

Requirements Disinfection Profiling and Benchmarking

• Lessons Learned in the Process (City of Manassas, VA) Other Requirements under the SWTR Turbidity Requirements

• Conventional and Direct Filtration Systems • Systems using Slow Sand, Diatomaceous Earth or Alternative

Filtration• Unfiltered Systems

Case Studies Additional Resources

Overview

12

The requirements that apply to each system depend on the system’s treatment

process.

Applicability to Systems

This presentation covers:

• Conventional and Direct Filtration Systems

• Slow Sand and Diatomaceous Earth or Alternative Filtration Systems

• Unfiltered Systems

Overview

13

Presenters

Ed Moriarty, U.S. EPA

Maria Lopez, U.S. EPA

Linda Hills, The Cadmus Group, Inc.

Tom Grubbs, U.S. EPA

Mike Finn, U.S. EPA

Panelists

Overview

14

Disclaimer

The examples included in this presentation are intended for discussion purposes only.  Throughout this presentation, the terms “state” or “states” are used to refer to all types of primacy agencies including U.S. territories, Indian tribes, and EPA Regions. The statutory provisions and EPA regulations described in this document contain legally binding requirements. This presentation is not a regulation itself, nor does it change or substitute for those provisions and regulations. Thus, it does not impose legally binding requirements on EPA, states, or public water systems. This guidance does not confer legal rights or impose legal obligations upon any member of the public. While EPA has made every effort to ensure the accuracy of the discussion in this presentation, the obligations of the regulated community are determined by statutes, regulations, or other legally binding requirements. In the event of a conflict between the discussion in this presentation and any statute or regulation, this presentation would not be controlling.

Overview

15

Public Health & Regulated Pathogens

Regulated Pathogens:

• Viruses

• Giardia

• Cryptosporidium

In excess amounts:

• Nausea

• Cramps

• Diarrhea

• Associated headaches

• More serious health effects for infants, elderly or other immune-compromised people

Overview

16

History of Microbials

17

The Challenge of Microbial Organisms What They Do Was Known

Before What They Are

• Hippocrates: Boil and Strain Water ~300BC

• Chlorination to Prevent ‘Child Bed Fever’ - 1846

• John Snow Closes the Broad Street Well, London, 1854 - Terminates Cholera Epidemic

What They Do Was Known Before How To Detect Them In Drinking Water

Overview

18

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

19

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

1974 – Safe Drinking Water

Act (SDWA)

Overview

20

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

21

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

1976 – National Interim Primary Drinking Water Regulations (NIPDWR): Coliform and Turbidity

22

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

23

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

1986 – Safe Drinking Water Act Amendments (SDWA

Amendments)

24

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

25

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

1989 – Total Coliform Rule (TCR); Surface Water

Treatment Rule (SWTR)

26

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

27

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

1996 – Safe Drinking Water Act Amendments (SDWA

Amendments)

28

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

29

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

1998 – Interim Enhanced Surface Water Treatment Rule

(IESWTR); Stage 1 Disinfectants and Disinfection Byproducts

Rule (S1DBPR)

30

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

31

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

2001 – Filter Backwash

Recycling Rule (FBRR)

32

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

33

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

2002 – Long Term 1 Enhanced Surface Water Treatment Rule

(LT1ESWTR)

34

History of M-DBP Regulations

THM – 1979 NPIDWRs –

1976 SDWA – 1974

MA Giardia Outbreak – 1985

SDWA Amendments – 1986

GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989

WI Crypto Outbreak – 1993 SDWA Amendments – 1996

IESWTR and S1DBPR – 1998

FBRR – 2001

2005 – Proposed S2DBPR, LT2ESWTR, GWR

200? – Future Rules: Revised TCR

LT1ESTWR – 2002

Overview

35

National Interim Primary Drinking Water Regulations (NIPDWR) Effective from 1975 to 1986 SDWA Amendments

Total Coliform Monitoring and MCL Based on USPHS Drinking Water Regulations of 1962

Turbidity MCL for Surface Water

Recognized Underreporting of Outbreaks

Overview

36

1996 SDWA Amendments

No Significant Changes to the Total Coliform Rule Required Promulgation of Microbial/Disinfection

Byproduct Regulations

• IESWTR, LT1ESWTR, FBRR, LT2ESWTR

• Stage 1 and 2 Disinfectants and Disinfection Byproducts Rules

Overview

37

6-Year Review Cycle

SDWA Requires Review of Existing Regulations The Total Coliform Rule is Under Review

• Schedule to Be Determined

Overview

38

Types of Filtration:

Conventional Filtration Direct Filtration Slow Sand Filtration Diatomaceous Earth Filtration Alternative Filtration Technologies

Overview

39

Requirements for Filtered Systems

Removal/Inactivation Requirements for Certain Pathogens

Residual Disinfectant Requirements Turbidity Treatment Techniques Disinfection Profiling and Benchmarking Sanitary Surveys Covered Finished Reservoirs/Water Storage Facilities Operator Certification

Overview

40

Requirements for Unfiltered Systems

Inactivation Requirements for Certain Pathogens Residual Disinfectant Requirements Filtration Avoidance Criteria Disinfection Profiling and Benchmarking Sanitary Surveys Covered Finished Reservoirs/Water Storage Facilities Operator Certification

Overview

41

Questions

Please send your questions & comments via the web console located on your bottom right.

Q & A

42

Overview of SWTR, IESWTR, and LT1ESWTR Requirements

Conventional and Direct Filtration Systems

Systems using Slow Sand, Diatomaceous Earth or Alternative Filtration

Unfiltered Systems

43

General Requirements

All Subpart H systems must comply with the following requirements:

• Removal/inactivation requirements for viruses, Giardia, and Cryptosporidium

• Residual disinfectant monitoring

• Disinfection profiling and benchmarking

• Sanitary surveys

• Covered finished reservoirs/water storage facilities

• Qualified operators

Unfiltered Systems

Conventional and Direct

Filtration

Slow Sand, Diatomaceous or Alternative

Filtration

44

Regulated Pathogens (Removal/Inactivation Requirements) All subpart H systems must comply with the

removal/inactivation requirements established for regulated pathogens. The removal/inactivation requirements are as follows:       

Microbial MCLGRemoval/Inactivation

Requirements

Viruses 99.99% (4-log)

Unfiltered Systems

Conventional and Direct

Filtration

Slow Sand, Diatomaceous or Alternative

Filtration

45

Regulated Pathogens (Removal/Inactivation Requirements) All subpart H systems must comply with the

removal/inactivation requirements established for regulated pathogens. The removal/inactivation requirements are as follows:       

Microbial MCLGRemoval/Inactivation

Requirements

Viruses 99.99% (4-log)

Giardia Lamblia Zero 99.9% (3-log)

Unfiltered Systems

Conventional and Direct

Filtration

Slow Sand, Diatomaceous or Alternative

Filtration

46

Regulated Pathogens (Removal/Inactivation Requirements) All subpart H systems must comply with the

removal/inactivation requirements established for regulated pathogens. The removal/inactivation requirements are as follows:       

Microbial MCLGRemoval/Inactivation

Requirements

Viruses 99.99% (4-log)

Giardia Lamblia Zero 99.9% (3-log)

Cryptosporidium Zero 99% (2-log) (removal only)

Unfiltered Systems

Conventional and Direct

Filtration

Slow Sand, Diatomaceous or Alternative

Filtration

47

Residual Disinfectant Monitoring Requirements

PopulationEntrance to Distribution

SystemIn Distribution System

All Subpart H Systems

Cannot be < 0.2 mg/L for more than 4 hours1

Detectable in at least 95% of samples in a month for any 2 consecutive months

1 Residual monitored continuously. A state may allow systems serving 3,300 or fewer persons to take grab samples from 1-4 times per day, depending on system size.

Unfiltered Systems

Conventional and Direct

Filtration

Slow Sand, Diatomaceous or Alternative

Filtration

48

Residual Disinfectant Reporting Requirements

Report to state due within 10 days of the end of the following month.

Remember to include:

A calculation of the percent of distribution residual

samples that were undetectable

Lowest daily value for each day

The date and duration when residual

disinfectant was <0.2 mg/L

When state was notified of events where residual

disinfectant was <0.2 mg/L

Unfiltered Systems

Conventional and Direct

Filtration

Slow Sand, Diatomaceous or Alternative

Filtration

49

Additional Disinfectant Monitoring Requirements

Frequency In Distribution System

Daily Before or at the first customer: Temperature pH (if chlorine is used) Disinfectant contact time(s) at peak hourly flow Residual disinfectant concentration measurement(s) at

peak hourly flow used in the inactivation calculation(s)

Unfiltered Systems

50

Additional Disinfectant Reporting Requirements

Daily residual disinfectant concentration(s) and

disinfectant contact time(s) used for calculating the CT

value(s).

As soon as possible, but no later than the end of the next business day. Remember to include:

Instances where the residual disinfectant

level entering the distribution system

was < 0.2 mg/L

Unfiltered Systems

Report to state due within 10 days of the end of the following

month. Remember to include:

51

Quiz #1: Disinfectant Residual Example System:

• Takes 3 routine TCR samples

• Uses Surface Water

• Has a Conventional Filtration

In addition to taking one sample at the entry point to the distribution systems, what does this system need to do to comply with the SWTRs residual disinfectant monitoring requirements?

Conventional and Direct

Filtration

52

Quiz #1: Disinfectant Residual

Entry Point

= Sample Location

Conventional and Direct

Filtration

System needs to take:

3 disinfectant residual samples at the same time

and place as the TCR sample

40 CFR 141.74 (b)(6)(i)

53

Quiz #2: Unfiltered System Reporting Requirements

What does this system need to report in order to comply with the SWTRs residual disinfectant monitoring requirements?

1)Daily residual disinfectant concentration(s) & disinfectant contact time(s) used for calculating the CT value(s)

2)Lowest daily value for each day

3)The date/duration when residual disinfectant was <0.2 mg/L

4)When state was notified of events where residual disinfectant was <0.2 mg/L

5)A calculation of the percent of distribution residual samples that were undetectable

6)All of the aboveUnfiltered Systems

Example Systems: Unfiltered, Surface Water system that serves 12,000 people

54

Quiz #2: Unfiltered System Reporting Requirements

What does this system need to report in order to comply with the SWTRs residual disinfectant monitoring requirements?

6)All of the above

Lowest daily value for each day

The date and duration when

residual disinfectant was

<0.2 mg/L

When state was notified of events

where residual disinfectant was

<0.2 mg/L

A calculation of the percent of distribution residual

samples that were undetectable

Daily residual disinfectant concentration(s) and disinfectant contact time(s) used for calculating the CT value(s).

Unfiltered Systems

Example Systems: Unfiltered, Surface Water system that serves 12,000 people

55

Quiz #3: Filtered System Reporting Requirement

What does this system need to report in order to comply with the SWTRs residual disinfectant monitoring requirements?

1)Lowest daily value for each day

2)The date and duration when residual disinfectant was <0.2 mg/L

3)When state was notified of events where residual disinfectant was <0.2 mg/L

4)A calculation of the percent of distribution residual samples that were undetectable

5)All of the aboveSlow Sand, Diatomaceous or Alternative

Filtration

Example Systems: GWUDI systems that serves 4,500 people that uses slow sand filtration and measures HPC in lieu of distribution disinfectant residuals.

56

Quiz #3: Filtered System Reporting Requirement

What does this system need to report in order to comply with the SWTRs residual disinfectant monitoring requirements?

5)All of the above

Slow Sand, Diatomaceous or Alternative

Filtration

Lowest daily value for each day

The date and duration when

residual disinfectant was

<0.2 mg/L

When state was notified of events

where residual disinfectant was

<0.2 mg/L

A calculation of the percent of distribution residual

samples that were undetectable

Example Systems: GWUDI systems that serves 4,500 people that uses slow sand filtration and measures HPC in lieu of distribution disinfectant residuals.

How long have you worked with the surface water rules (base your response on the average in the room) 0-6 Months 7-12 Months 1-2 Years 2-4 Years 4+ Years

58

Questions

Please send your questions & comments via the web console located on your bottom right.

Q & A

59

Disinfection Profiling and Benchmarking

60

Disinfection Profiling and Benchmarking A “Snap-Shot” Ensures Microbial Protection 3-Step Process

1. Applicability Determination

2. Profiling

3. Benchmarking and Consultation

Slow Sand, Diatomaceous or Alternative

Filtration

Unfiltered Systems

Conventional and Direct Filtration

61

Disinfection Profiling and Benchmarking Applies to: all Subpart H

PWSs Profiling requirements vary

by system size

Disinfection benchmark must be calculated and State must be consulted if the system is considering:

• Changes to the point of disinfection

• Changes to the disinfecant(s) used

• Changes to the disinfection process

• Any other modification identified by the state.

Slow Sand, Diatomaceous or Alternative

Filtration

Unfiltered Systems

Conventional and Direct

Filtration

40 CFR 141.172 and 141.530

62

Why Develop a Disinfection Profile and Benchmark? A Regulatory Threshold to Be Achieved The Threshold Is Often Exceeded Assess Affects of Treatment Changes Upon Actual

Inactivation Consider:

• Positive and Negative Impacts

• Acute and Chronic Health Risks

• Alternatives Public Health Based Decision

Slow Sand, Diatomaceous or Alternative

Filtration

Unfiltered Systems

Conventional and Direct Filtration

63

To Distribution

Why Develop a Disinfection Profile & Benchmark?

Filters

Contact Basin

Flocculation Basins

Potential Chlorination Points

SedimentationBasin

Lake1

2

3

4

Slow Sand, Diatomaceous or Alternative

Filtration

Unfiltered Systems

Conventional and Direct Filtration

64

Month Week Log Inact. Giardia

Month Week Log Inact. Giardia

JAN 1 1.34 JULY 27 1.86 2 1.35 28 1.82 3 1.38 29 1.76 4 1.37 30 1.74

FEB 5 1.38 AUG 31 1.71 6 1.38 32 1.70 7 1.39 33 1.66 8 1.40 34 1.61

MARCH 9 1.40 SEP 35 1.60 10 1.40 36 1.55 11 1.41 37 1.56 12 1.42 38 1.52 13 1.43 39 1.51

APRIL 14 1.46 OCT 40 1.47 15 1.50 41 1.48 16 1.54 42 1.47 17 1.57 43 1.47

MAY 18 1.64 NOV 44 1.45 19 1.66 45 1.41 20 1.70 46 1.43 21 1.72 47 1.41

JUNE 22 1.74 DEC 48 1.40 23 1.77 49 1.40 24 1.79 50 1.40 25 1.82 51 1.40 26 1.81 52 1.37

04/19/23 Conventional and Direct Filtration

Example Disinfection Profile

0.000

0.200

0.400

0.600

0.800

1.000

1.200

1.400

0 4 8 12 16 20 24 28 32 36 40 44 48 52

Week Tested

Lo

g In

acti

vati

on

, Giardia

Log Inactivation

66

LT1ESWTR Profiler

www.LT1P.com

67

Disinfection Profile and Benchmark

“Lessons Learned in the Process”

Alexander Vanegas

City of Manassas

June 2005

68

EPA Sets Guidelines

The purpose of developing the disinfection profile and benchmark is to provide a basis for the water system and the state primacy agency to work together to assure that any changes in disinfection practices to meet new disinfection byproduct MCLs will not result in a significant reduction in the microbial protection provided by the system.

69

EPA Sets Guidelines

In order to determine if profiling was necessary, water utilities were to conduct four quarters of "Applicability Monitoring" for TTHMs and HAAs. If the TTHM or HAA annual averages from the applicability monitoring exceeded 64 ppb or 48 ppb, respectively, the water system needed to prepare a disinfection profile.

70

Crypto & Giardia Removal All surface water systems that serve more than l0,000

people and are required to filter must achieve at least:

• 2 log removal of Cryptosporidium or 99% removal based on treatment technique

• 3 log removal of Giardia lamblia or 99.9% removal/inactivation based on treatment technique.

• 4 log removal of viruses or 99.99% removal/inactivation based on treatment technique.

71

Timeline of Problems

January 2002 - TTHM & HAA MCL reduced from 100ppb -80ppb respectively to 80-60 ppb.

November 2002 - Manganese violation (0.05 mg/L) December 2002 - Exceeding TTHMs MCL and

difficulty meeting TOC removal December 2002 - Inverted application of Chlorine

from heavy Pre-CL 2 in Rapid Mix and low concentration in clearwell to low Pre-CL 2 in Rapid Mix and higher concentration in clearwell.

72

Timeline: Action Steps taken to Obviate the Situation January 2003 - Switched coagulant from Aluminum

Sulfate to Ferric Chloride to assist in TOC removal and reduce TTHMs.

October 2003 - Moved CL2 application point from rapid mix to pre-filter area after sedimentation basins.

January 2004 - Switched from Gaseous Chlorine to Sodium Hypochlorite

73

Timeline: Action Steps taken to Obviate the Situation September 2004 - Replaced GAC media

December 2004 - Lead & Copper exceeds limits requiring action. (15 ppb)

May 2005 - Switched to Ferric Sulfate.

74

January 2003—Switched to Ferric Chloride Switched from Alum Common trend in industry Assist with TOC removal and increased NOM

removal Implications

75

October 2003—Chlorine Application

Moved Chlorine Application Point Originally at Rapid Mix prior to Sedimentation New location prior to filters after sedimentation.

76

January 2004—Switch to NaOCL

Sodium hypochlorite, (NaOCl) offers an excellent alternative approach to disinfection. The active ingredient is the hypochlorite ion OCl—, which hydrolyzes to form hypochlorous acid (HOCl).

77

January 2004—Switch to NaOCL Often called liquid bleach, is considered to be the

second cheapest disinfectant after bulk liquid chlorine gas. Commercially available as a 12.5 percent solution, it offers most of the advantages of chlorine gas–as a disinfectant, oxidizing agent and residual disinfectant, yet it does not have transportation or storage hazards to the extent present with chlorine gas.

Impetus driven by Vulnerability Assessment & reduction of potential hazard in area of high development.

78

Disinfection Profile 2002Disinfection Profile

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2 21 2 2 2 2 2 2 2 2 3 31

Day of the Month

Inactivation Ratio Logs of Inactivation

79

Disinfection Profile 2003Disinfection Profile

0.00

1.00

2.00

3.00

4.00

5.00

6.00

7.00

8.00

9.00

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2 21 2 2 2 2 2 2 2 2 3 31

Day of the Month

Inactivation Ratio Logs of Inactivation

80

Disinfection Profile 2005Disinfection Profile

0.00

2.00

4.00

6.00

8.00

10.00

12.00

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2 21 2 2 2 2 2 2 2 2 3 31

Day of the Month

Inactivation Ratio Logs of Inactivation

81

Comparison of Water Quality

Prior to Changes 2002 TTHMs - 97 ppb RAA HAA5 - 35 ppb RAA TOC removal

• 41% highest

After Changes 2004 TTHMs - 55 ppb RAA HAA5 - 30 ppb RAA TOC removal

• 64% highest

Is the person or persons responsible for implementing the surface water rules attending this training? Yes No Not Sure.

83

Questions

Please send your questions & comments via the web console located on your bottom right.

Q & A

84

Other Requirements

Conventional and Direct Filtration Systems

Systems using Slow Sand, Diatomaceous Earth or Alternative Filtration

Unfiltered Systems

85

Other Requirements

Sanitary Surveys

• Community Water Systems: Every 3 years

• Noncommunity Water Systems: Every 5 Years

Covered Finished Water Reservoirs/Water Storage Facilities

Certified Operator

Conventional and Direct

Filtration

Slow Sand, Diatomaceous or Alternative

Filtration

Unfiltered Systems

86

Filter Backwash Recycling Rule. (FBRR) Purpose: To improve public health protection by

assessing and changing, where needed, recycle practices for improved contaminant control, particularly microbial contaminants.

Applies to Subpart H conventional or direct filtration systems that:

• Recycle spent filter backwash, thickener supernatant, or liquids from dewaterting processes

Conventional and Direct

Filtration

87

FBRR Requirements

Return recycle flows through all unit processes at treatment system or alternative location approved by the states

Collecting and retaining recycle flow information

Completing all capital improvements associated with relocating recycle return location by June 8, 2006

Conventional and Direct

Filtration

88

PN Rule Requirements (Tier 1)

Exceedance of maximum turbidity level

• Conventional and direct filtration

• Slow sand, diatomaceous earth, and alternative filtration

• Unfiltered Waterborne disease outbreak

Unfiltered Systems

Slow Sand, Diatomaceous or Alternative

Filtration

Conventional and Direct

Filtration

89

PN Rule Requirements (Tier 1)

Tier 1: Notify the state within 24 hours of the violation!

• For turbidity, State will determine whether violation is Tier 1 or Tier 2

• Notify customers within 24 hours if violation is Tier 1

• Design communication to reach all users

• Send a copy to the state within 10 days of notifying customers

Unfiltered Systems

Slow Sand, Diatomaceous or Alternative

Filtration

Conventional and Direct

Filtration

90

Violations Requiring Tier 2 PN Turbidity violations

• Single exceedance – As determined by the state• 95th percentile exceedance

Failure to perform profiling Failure to consult with state prior to changing disinfection

practices Inactivation violations > 5 percent undetectable distribution residuals Failure to meet avoidance criteria Failure to recycle to an appropriate location (FBRR) Failure to complete capital improvements by required schedule

(FBRR)

Unfiltered Systems

Slow Sand, Diatomaceous or Alternative

Filtration

Conventional and Direct

Filtration

91

Notify customers within 30 days

Send a copy of PN to the state within 10 days of notifying customers

PN Rule Requirements (Tier 2)

Tier 2: Notify the state within 48 hours of the violation!

Unfiltered Systems

Slow Sand, Diatomaceous or Alternative

Filtration

Conventional and Direct

Filtration

92

PN Rule Requirements (Tier 3)

All Monitoring and Reporting Violations

Unfiltered Systems

Slow Sand, Diatomaceous or Alternative

Filtration

Conventional and Direct

Filtration

93

Notify customers within 12 months

Send a copy of PN to the state within 10 days of notifying customers

Notification may be included in CCR

PN Rule Requirements (Tier 3)

Unfiltered Systems

Slow Sand, Diatomaceous or Alternative

Filtration

Conventional and Direct

Filtration

94

Questions

Please send your questions & comments via the web console located on your bottom right.

Q & A

95

Turbidity Requirements

Conventional and Direct Filtration Systems

Systems using Slow Sand, Diatomaceous Earth or Alternative Filtration

Unfiltered Systems

96

Turbidity

Combined Filter Effluent (CFE)

Individual Filter Effluent (IFE)

Conventional and Direct

Filtration

Slow Sand, Diatomaceous or Alternative

Filtration

97

Conventional and Direct Filtration Systems

Conventional and Direct Filtration

98

CFE Requirements

Monitoring Requirement

Monitoring Frequency

Measurement

CFE 95% Value At least every 4 hours

< 0.3 NTU

Conventional and Direct Filtration

99

CFE Requirements

Monitoring Requirement

Monitoring Frequency

Measurement

CFE 95% Value At least every 4 hours

< 0.3 NTU

CFE Maximum Value

At least every 4 hours

1 NTU

Conventional and Direct

Filtration

100

CFE Reporting

Report to state due within 10 days of the end of the following month. Remember to include:

Percentage of CFE measurements <

95th % limit

Date and Value of any CFE

measurement that exceeded 1

NTU

Total number of CFE

measurements

Conventional and Direct

Filtration

101

CFE Exceedance Reporting(Systems serving at least 10,000 people)

Report to state as soon as possible, but no later than the end of the next

business day

Exceedance of 1 NTU

Conventional and Direct

Filtration

102

IFE Monitoring Requirements (Systems serving at least 10,000 people) IFE must be monitored continuously every 15

minutes

Conventional and Direct

Filtration

103

IFE Follow-up Steps (Systems serving at least 10,000 people)

Condition Action

1 2 consecutive measurements >0.5 NTU taken 15 minutes apart at the end of the first 4 hours of continuous filter operation after backwash/offline

Produce filter profile within 7 days (if cause is not known)

2 2 consecutive measurements >1.0 NTU taken 15 minutes apart

Produce filter profile within 7 days (if cause is not known)

3 2 consecutive measurements >1.0 NTU taken 15 minutes apart at the same filter for 3 months in a row

Conduct a filter self-assessment within 14 days

4 2 consecutive measurements >2.0 NTU taken 15 minutes apart at the same filter for 2 months in a row

Arrange for a CPE within 30 days and submit report within 90 days

Conventional and Direct

Filtration

104

IFE Reporting – Conditions 1, 2, and 3

Report to state due within 10 days of the end of the following month.

Remember to include:

Filter Number

Turbidity Value

Cause (if known) or report profile

was produced

Date

Conventional and Direct

Filtration

105

IFE Reporting – Condition 4

Report to state due within 10 days of the end of the

following month. Remember to include:

Filter Number

Turbidity Value

Date

Submit CPE Report

Schedule & conduct CPE.

Report to state due within 90 days

after exceedance:

Conventional and Direct

Filtration

106

IFE Monitoring Requirements (Systems serving fewer than 10,000 people) IFE must be monitored continuously every 15

minutes

Conventional and Direct

Filtration

107

IFE Follow-up Steps (Systems serving fewer than 10,000 people)

Conventional and Direct

Filtration

Condition Action

1 2 consecutive measurements >1.0 NTU taken 15 minutes apart

Reporting only

2 2 consecutive measurements >1.0 NTU taken 15 minutes apart at the same filter for 3 months in a row

Conduct a filter self-assessment within 14 days

3* 2 consecutive measurements >2.0 NTU taken 15 minutes apart at the same filter for 2 months in a row

Arrange for a CPE within 60 days and submit report within 120 days

* Exception if a CPE was done in the last 12 months

108

IFE Reporting – Condition 1

Report to state due within 10 days of the end of the following month.

Remember to include:

Filter Number

Turbidity Value

Cause (if known)

Date

Conventional and Direct

Filtration

109

IFE Reporting – Condition 2

Report to state due within 10 days of the end of the following month (or within 14

days of filter self-assessment being triggered if triggered in the last 4 days of

the month). Conduct filter self-assessment. Report:

Date the filter self-assessment was triggered

Date the filter self-assessment was completed

Conventional and Direct

Filtration

110

IFE Reporting – Condition 3

Report to State due within 10 days of the end of the following month.

Schedule & Conduct CPE. Remember to

include:

Date CPE was triggered

Submit CPE Report

CPE report to State due within 120 days after exceedance:

Conventional and Direct

Filtration

111

Case Studies: Great View Filtered Surface Water System, Serving 15,000

People, Using Direct Filtration

• Where, when, & how many CFE samples should this system take?

• What is the limit for the CFE 95th% value?

• What is the system required to report to the state within 10 days?

• Where & how many IFE samples should this system take?

• Two consecutive IFE measurements are >1.0 NTU What is the system required to do?

Case Study

Where, when, & how many CFE samples should this system take? One per year at the source Five samples per month in the distribution system At least one sample every 4 hours from the combined

filter effluent

113

Answer

Where, when, & how many CFE samples should this system take?

• At least one sample every 4 hours from the combined filter effluent

Direct Filtration System, serving

15,000

Case Study

What is the limit for the CFE 95th% value?

1.2 mg/L 1.0 NTU <= 0.3 NTU None of the above

115

Answer

What is the limit for the CFE 95th% value?

• <= 0.3 NTU

Direct Filtration System, serving

15,000

Case Study

What is the system required to report to the state within 10 days? Percentage of CFE measurements <= 95th% limit Date and value of any CFE measurement that

exceeded 1 NTU Total number of CFE measurements All of the above

117

Answer

What is the system required to report to the state within 10 days?

• All of the above

Direct Filtration System, serving

15,000

Case Study

Where & how many IFE samples should this system take? 1 sample at the entry point to the distribution system 2 samples in the source water Continuously monitor every 15 minutes from the

individual filter effluent At least every 4 hours at the entry point to the

distribution system

119

Answer

Where & how many IFE samples should this system take?

• Continuously monitor every 15 minutes from the individual filter effluent

Direct Filtration System, serving

15,000

Case Study

Two consecutive IFE measurements are >1.0 NTU. What is the system required to do? If the cause cannot be determined, produce a filter

profile within 7 days Report filter number, turbidity value(s) and date by

the 10th of the following month Report the cause, or report that a filter profile has

been completed, by the 10th of the following month, All of the above

121

Answer

Two consecutive measurements are >1.0 NTU. What is the system required to do?

• All of the above.

Direct Filtration System, serving

15,000

Case Study

122

Questions

Please send your questions & comments via the web console located on your bottom right.

Q & A

123

Systems using Slow Sand, Diatomaceous Earth or Alternative Filtration

Slow Sand, Diatomaceous or

Alternative Filtration

124

CFE Requirements

Monitoring Requirement

Monitoring Frequency

Measurement

CFE 95% Value At least every 4 hours

< 1 NTU

Slow Sand, Diatomaceous or Alternative

Filtration

125

CFE Requirements

Monitoring Requirement

Monitoring Frequency

Measurement

CFE 95% Value At least every 4 hours

< 1 NTU

CFE Maximum Value

At least every 4 hours

5 NTU

Slow Sand, Diatomaceous or Alternative

Filtration

126

CFE Reporting

Report to state due within 10 days of the end of the following month. Remember to

include:

Total number of monthly

measurements

Number and percent of monthly measurements less then or equal to designated

95th percentile turbidity limits

Date and value exceeding 5 NTU for slow sand and

diatomaceous earth filtration or maximum level set by the state for alternative filtration

Slow Sand, Diatomaceous or Alternative

Filtration

127

CFE Exceedance Reporting

Report to state as soon as possible, but no later than the end of the next business day :

Exceedance of 5.0 NTU for slow sand and diatomaceous earth filtration or maximum level set by the state for

alternative filtrationSlow Sand,

Diatomaceous or Alternative

Filtration

128

Case Studies: Plain Valley Filtered GWUDI System, Serving 300 People, Using

Slow Sand Filtration

• What is the reduced monitoring frequency that the state can set for this system?

• What is the maximum CFE limit?

• What is the system required to report to the state within 10 days?

• What are the removal/inactivation requirements for Viruses, Giardia Lamblia, and Cryptosporidium for this system?

• How many IFE samples should this system take?Case Study

What is the reduced monitoring frequency that the state can set for this system? At least every 8 hours One sample per day Continuous monitoring every 2 hours Four samples per day

130

Answer

What is the reduced monitoring frequency that the state can set for this system?

• One sample per day

Case Study

GWUDI System, serving 300 using

slow sand filtration

What is the maximum CFE limit?

<= 1 NTU 5 NTU <= 0.3 NTU None of the above

132

Answer

What is the maximum CFE limit?

• 5 NTU

Case Study

GWUDI System, serving 300 using

slow sand filtration

What is the system required to report to the state within 10 days? Total number of monthly measurements Number and percent less than or equal to designated

95% turbidity limits Date and value exceeding 5 NTU All of the above

134

Answer

What is the system required to report to the state within 10 days?

• All of the above

Case Study

GWUDI System, serving 300 using

slow sand filtration

What are the removal/inactivation requirements for Viruses, Giardia Lamblia, and Cryptosporidium for this system? Viruses - 4-log removal/inactivation, Giardia

Lamblia - 3-log removal/inactivation, Cryptosporidium - 2-log removal

Viruses - 2-log removal/inactivation, Giardia Lamblia - 2-log removal/inactivation, Cryptosporidium - 3-log removal

Viruses - 3-log removal/inactivation, Giardia Lamblia - 4-log removal/inactivation, Cryptosporidium - 4-log removal

136

Answer

What are the removal/inactivation requirements for Viruses, Giardia Lamblia, and Cryptosporidium for this system?

• Viruses - 4-log removal/inactivation, Giardia Lamblia - 3-log removal/inactivation, Cryptosporidium - 2-log removal

Case Study

GWUDI System, serving 300 using

slow sand filtration

How many IFE samples should this system take? At least every 4 hours Continuous monitoring every 15 minutes Not required Once per day

138

Answer

How many IFE samples should this system take?

• Not required.

Case Study

GWUDI System, serving 300 using

slow sand filtration

139

Unfiltered Systems

Unfiltered Systems

140

Filtration Avoidance Criteria

Source Water Conditions

• Turbidity

• Microbial quality Inactivation and Disinfectant Residual Watershed Control and Inspection

Unfiltered Systems

141

Source Water Conditions (Turbidity)

Requirement Frequency Measurement

Source Water Samples

At least every 4 hours

< 5 NTU on two consecutive days

Unfiltered Systems

142

Source Water Conditions (Microbial Quality)

Requirement Frequency Measurement

Fecal coliform

1 – 5 samples per week depending on system size and every day the turbidity of the source water exceeds 1 NTU

< 20/100 mL

And/Or

Total coliform

1 – 5 samples per week depending on system size and every day the turbidity of the source water exceeds 1 NTU

< 100/100 mL

Unfiltered Systems

143

Reporting Requirements

Report to state within 24 hours.

Turbidity exceedances of 5

NTU

Waterborne disease

outbreaks

Unfiltered Systems

144

Upcoming Regulations

Expected final in December 2005

• Stage 2 DBPR

• LT2ESWTR

Additional Resources

145

LT2ESWTR Preview Objective: Risk-based targeting approach to reduce exposure

to Cryptosporidium in public water systems.

• Target filtered systems with high source water Cryptosporidium levels where 99% (2-log) removal is not sufficient treatment

• Target all unfiltered systems, which currently provide no treatment

Components of LT2ESWTR:

• Filtered systems assigned to different “risk bins” based on results of source water Cryptosporidium monitoring

Additional Cryptosporidium treatment based on bin classification “Microbial Toolbox” of options – flexibility in meeting

additional treatment requirements

146

LT2ESWTR Preview

Additional LT2ESWTR requirements:

• Specific requirements for uncovered finished water reservoirs and unfiltered systems.

• Second round of monitoring 6 years following initial bin assignment.

• Disinfection profiling and benchmarking.

147

Evaluation Form – Available on the web at:

• http://yosemite.epa.gov/ogwdw/ogwdwsurvey.nsf/surveyhome?openform

• Enter code: survey07 Please email webcastinfo@cadmusgroup.com if

you have questions

Join us for Data Verification Webcast Training

Wednesday, July 27, 2005, 2 – 4 PM

Join us for Data Verification Webcast Training

Wednesday, July 27, 2005, 2 – 4 PMDon’t Forget

148

Questions?

Please send your questions & comments via the web console located on your bottom right.

Q & A

149

Additional Resources

150

Webcast Materials

Drinking Water Academy Web site: www.epa.gov/safewater/dwa.html

• Webcast Presentation Slides

• Written Q&A from Webcast Will Be Emailed To All Registered Participants

Additional Resources

151

Additional Resources

Quick Reference Guides:

• IESWTR (EPA 816-F-01-011)

• LT1ESWTR (EPA 816-F-02-001)

• FBRR (EPA 816-F-01-019) Technical guidance documents:

• Alternative Disinfectants and Oxidants Guidance Manual (EPA 815-R-99-014)

• Disinfection Profiling and Benchmarking Guidance Manual (EPA 815-R-99-013)

• Enhanced Coagulation and Enhanced Precipitative Softening Guidance Manual (EPA 815-R-99-010)Additional

Resources

152

Additional Resources

Technical guidance documents (continued):

• Guidance Manual for Compliance with the Interim Enhanced Surface Water Treatment Rule: Turbidity Provisions (EPA 815-R-99-010)

• Guidance Manual for Conducting Sanitary Surveys of Public Water Systems; Surface Water and Ground Water Under the Direct Influence (GWUDI) (EPA 815-R-99-016)

• M/DBP Simultaneous Compliance Manual (EPA-815-R-99-015)

• Uncovered Finished Water Reservoirs Guidance Manual (EPA 815-R-99-011)

Additional Resources

153

Additional Resources

Technical guidance documents (continued):

• Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR) Implementation Turbidity Provisions - Technical Guidance Manual (EPA 816-R-04-007)

• Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR) Disinfection Profiling and Benchmarking Technical Guidance Manual (EPA 816-R-03-004)

• Filter Backwash Recycling Rule Technical Guidance Manual (EPA 816-R-02-014)

• Technical Fact Sheet: Final Filter Backwash Recycling Rule (EPA 815-F-01-001)

Additional Resources

154

Additional Resources Implementation guidance documents:

• IESWTR Final Implementation Guidance (EPA 816-R-01-011)

• LT1 Final Implementation Guidance (EPA 816-R-04-008)

• FBRR Final Implementation Guidance (EPA 816-R-04-006)

• IESWTR Plain English Guidance (EPA 816-R-01-014)

• Profiling and Benchmarking Fact Sheet (EPA 816-F-98-017b)

• IESWTR Fact Sheet (EPA 816-F-01-013)

Additional Resources

155

EPA Resources Available

All documents available through

• EPA’s Web site http://www.epa.gov/safewater/

OR

• By calling the Safe Drinking Water Hotline 1-800-426-4791

Additional Resources

156

For More Questions

Send Your State’s SWTRs Questions or Situations to:

• MDBP_OGWDW@epa.gov

• SWTRs Questions: Call your EPA Regional Office or Ed Moriarty, US EPA HQ 202-564-3864

Additional Resources

157

Next Webcast: Data Verifications

July 27, 2005, 2 – 4 PM (EST)

• For State Staff Only Overview of the EPA Headquarters-sponsored DV

process Example of process using TCR and Stage 1 DBPR as

examples

• Send your DV questions via email to: webcastinfo@cadmusgroup.com

Additional Resources

158

Webcast Series See Handout or DWA Calendar for Upcoming 2005

Webcasts

• http://www.epa.gov/safewater/dwa/calendar.html Future Webcasts will:

• Cover a Variety of Subjects and Rules

• Be Held Last Wednesday of the Month from 2-4 PM (Eastern Time)

• Have the Same Registration Process as for SWTRs

• Will Open for Registration Six Weeks Prior to Each Webcast

Additional Resources

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