long term 2 (lt2) surface water treatment rule...crypto level 19 system a system b source water...
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Long Term 2 (LT2) Surface Water
Treatment Rule
Round 2: What you need to know
Long Term 2 Enhanced Surface Water
Treatment Rule – Presentation Outline
Introduction of the Rule - Why Cryptosporidium
Federal Requirements
Sampling
Reporting
Analysis and Round One Experience – Laboratory
Questions
Round One Experience – Regulators and Utilities
Round Two – Group Discussion
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LT2 - Chronology
• SWTR (1989)
• SDWA Amendments (1996)
• DBP1 and IESWTR (1998)
• DBP2 and LT2ESWTR (2006)
• DBP3 and rTCR (Future)
LT2 Purpose = to reduce pathogen (GI) illness
Introduction of the Rule
History:
Disinfection of drinking water is one of the major
public health advances in the 20th century.
100 years ago, typhoid and cholera epidemics were
reduced by disinfection.
In the past 15 years, we found specific microbial
pathogens, such as Cryptosporidium, which can
cause illness, and are highly resistant to traditional
disinfection practices.
Disinfectants themselves can react with naturally-
occurring materials in the water to form byproducts,
which may pose additional health risks.
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Introduction of the Rule (cont)
1996 SDWA amendments
• Require EPA to develop rules to balance the risks between
microbial pathogens and disinfection byproducts (DBPs)
• Stage 1 Disinfectants and Disinfection Byproducts Rule and
Interim Enhanced Surface Water Treatment Rule (promulgated
in December 1998) were the first phase in a rulemaking
strategy.
LT2 and the Stage 2 DBP Rule are the second phase of
rules required by Congress.
• Strengthen protection against microbial contaminants,
especially Cryptosporidium, and at the same time, reduce
potential health risks of DBPs
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Introduction of the Rule (cont)
Purpose:
To reduce disease incidence associated with
Cryptosporidium and other disease-causing
microorganisms in drinking water
Improve public health protection
Introduction of the Rule (cont)
Ensures that systems maintain microbial protection as they take
steps to reduce the formation of disinfection byproducts
Addresses the need for filtered public water systems (PWSs)
with higher levels of source water Crypto contamination to
provide additional risk-based treatment for Crypto beyond the
IESWTR or LT1ESWTR requirements
Addresses the need for unfiltered PWSs to provide risk-based
treatment for Crypto to achieve equivalent public health
protection with filtered PWSs
Addresses the need for PWSs with uncovered finished water
storage facilities to take steps to reduce the risk of
contamination of treated water prior to distribution to
consumers
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Why Cryptosporidium?
• Cryptosporidium oocysts are highly resilient and can
survive filtration and disinfection processes
• Resistant to chlorine
• One of the most common causes of waterborne
disease in humans in the U.S.
• Gastrointestinal illness, which may be severe and
potentially fatal to at risk populations
• Methodology also reports Giardia
Why Cryptosporidium (cont)?
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1993: Cryptosporidium outbreak in Wisconsin
• 400,000+ illnesses
• 50+ deaths
2006: Five states reported outbreaks associated with
recreational water use.
2008: Study on 160 public swimming pools from 2
metro Atlanta counties showed 13 were positive for
one or both of the contaminants (Crypto and/or
Giardia).
Benefits & Costs
Benefits
EPA estimates that full compliance with LT2 will reduce
the incidence of gastrointestinal illness caused by
ingestion of Cryptosporidium by:
• ~ 90,000 – 1.4 million cases per year
• ~ 20 – 300 premature deaths
• Monetized benefits ~$253 million - $1.4 billion
Costs
• EPA estimated range from ~ $92-$133 million.
• Public water systems bear ~99% of costs, states incurring ~1%
• Average annual household cost estimated to be $1.67-$2.59/yr.
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LT2 REQUIREMENTS
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Federal (USEPA)
Requirements of
the Rule
Federal (USEPA)
LT2 Round One
Report to EPA
USEPA Laboratory Certification
LT2 Round Two
Report to the State
State by State Lab Certification Criteria
• CA = ELAP approval, NV = Federal List
• Or EPA in some States
• Or NELAC in some States
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Applies to all public water systems using
surface water sources or GWUDI sources
Compliance deadlines are based on number
of people served
Divided into four schedules
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Federal (USEPA)
LT2 – Monitoring Requirements
Turbidity (Certified Operator)
E.Coli (State Certified Lab)
Crypto (EPA/State Approval Lab)
• EPA 1622 (Crypto only)
• EPA 1623 (EnviroCheck, EasySeed)
• EPA 1623.1 (AccuSpike, Pellet Wash)
Applicability
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Population Served…> 100,000
(Schedule 1)1
50,000 – 99,999
(Schedule 2)1
10,000 – 49,999
(Schedule 3)1
<10,000
(Schedule 4)1,2
<10,000
(Schedule 4)1,3
Report Sampling Schedules &
Locations For Round II Source
Water MonitoringJanuary 1, 2015 July 1, 2015 July 1, 2016 July 1, 2017 January 1, 2019
Begin Round II Source Water
Monitoring April 1, 2015 October 1, 2015 October 1, 2016 October 1, 2017 April 1, 2019
Report Bin Classification &
Supporting Data from Round II
Monitoring October 1, 2017 April 1, 2018 April 1, 2019 April 1, 2020 October 1, 2022
1 Schedule is defined by the largest system in your combined distribution system2 Applies to filtered system (E. coli only) 3 Applies to unfiltered systems and those filtered systems that exceed the E. coli trigger or do not monitor for E. coli (Crypto)
Requirements of the Rule
Filtered water systems must reduce source water
Crypto levels by 99% (2-log)
Additional treatment is necessary for higher risk
systems
• Filtered systems with high levels of crypto
• All unfiltered water systems
Understanding “log” removal
Percent of Crypto that
is removed or inactivated by
treatment or other measures
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Requirements of the Rule (cont)
‘Log’ Removal Example 1
Both systems provide the same level of Crypto
removal/inactivation, but System B provides
higher quality finished water
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System A (unprotected) System B (pristine)
Source Water 100,000 Crypto oocysts 100 Crypto oocysts
Crypto Reduction 2-log removal /inactivation (99%) 2-log removal /inactivation (99%)
Finished Water 1,000 Crypto oocysts 1 Crypto oocyst
Requirements of the Rule (cont)
‘Log’ Removal Example 2
Both systems provide the same public health
protection, but System A must provide a higher
degree of treatment to get there
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System A (unprotected) System B (pristine)
Source Water 100,000 Crypto oocysts 100 Crypto oocysts
Crypto Reduction 5-log removal /inactivation (99.999%) 2-log removal /inactivation (99%)
Finished Water 1 Crypto oocysts 1 Crypto oocyst
Requirements of the Rule (cont)
‘Log’ Removal Example 3
System A is able to produce higher quality
finished water than System B, even though
Systems A and B have the same source water
Crypto level
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System A System B
Source Water 1,000 Crypto oocysts 1,000 Crypto oocysts
Crypto Reduction 3-log removal /inactivation (99.9%) 2-log removal /inactivation (99%)
Finished Water 1 Crypto oocysts 10 Crypto oocyst
Bin and Treatment Overview – Filtered
Filtered PWSs will be classified in one of four treatment
categories (“bins”) based on the results of the source water
Crypto monitoring
Bin classification determines the degree of additional Crypto
treatment, if any, the filtered PWS must provide
Occurrence data indicate that most filtered PWSs will be
classified in Bin 1, which carries no additional treatment
requirements
PWSs classified in Bins 2, 3, or 4 must achieve an additional 1.0-
to 2.5-log of treatment (i.e., 90 to 99.7 percent reduction) for
Crypto over and above the 2-log removal currently provided
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Requirements of the Rule (cont)
Requirements of the Rule (cont)
Bin and Treatment Overview – Unfiltered
Unfiltered systems’ treatment requirements are based
on the results of their initial source water monitoring:
• Unfiltered systems with a mean Crypto level of 0.01
oocysts/L or less must provide at least 2-log Crypto
inactivation
• Unfiltered systems with a mean Crypto level of greater than
0.01 oocysts/L must provide at least 3-log Crypto
inactivation
• This must be accomplished using a minimum of two
disinfectants
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Requirements of the Rule (cont)
Bin Classification
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For PWSs that are:With a Cryptosporidium bin
concentration of …
The bin classification
is . . .
*** required to
monitor for
Cryptosporidium
less than 0.075 oocysts/L Bin 1
0.075 oocysts/L or higher, but less than
1.0 oocysts/LBin 2
1.0 oocysts/L or higher, but less than
3.0 oocysts/LBin 3
3.0 oocysts/L or higher Bin 4
* * * serving fewer
than 10,000 people
and NOT required to
monitor for
Cryptosporidium1
NA Bin 1
Calculating Risk Bin Classification
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• If collecting monthly for 2 years
• Bin classification is calculated by averaging each 12 month
period over the 2 years
– (April 2015-March 2016, May 2015-April 2016, etc)
• Highest 12 month average would be used to determine bin
classification
• If collecting twice monthly for 2 years
• Average all 48 samples from the 2 year period
Calculating Risk Bin Classification
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Example 1: Collecting 1 sample monthly for 2 years. Highest
12 month average would be used to determine bin
classification
Average for April 2015-March 2016 = 6 oocysts/ 123.5 L = 0.048 oocysts/L
Highest Average is Oct. 2015-Sept. 2016 = 10 oocysts/ 124.5L =
0.080 oocysts/L (BIN 2)
Month April
2015
May June July August Sept. Oct. Nov. Dec. Jan.
2016
Feb. March
Oocysts 0 0 1 2 2 0 0 0 0 0 0 1
Volume
filtered
in liters
10 10 10.5 10 11 10 10 10.5 10 10 10.5 11
Month April
2016
May June July August Sept. Oct. Nov. Dec. Jan.
2017
Feb. March
Oocysts 0 0 3 3 2 1 0 0 0 0 0 0
Volume
filtered
in liters
10 10.5 11.5 10 10.5 10 10 10.5 10 10 10 10
Calculating Risk Bin Classification
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Example 2: Collecting twice monthly for 2 years. Average all
48 samples from the 2 year period
Average for all 48 samples = 21 oocysts/ 489 L = 0.043 oocysts/L (Bin 1)
Difference in cost of additional testing versus cost of additional treatment
for Bin 2 classification is significant!
Month April
2015
May June July August Sept. Oct. Nov. Dec. Jan.
2016
Feb. March
Oocysts 0/0 0/0 0/1 1/2 2/1 0/0 0/0 0/0 0/0 0/0 0/0 0/1
Volume
filtered
in liters
10/10 10/10 10/10.5 10/10 11/10.5 10/10 10/10 10.5/10 10/10 10/10 10/10.5 11/11
Month April
2016
May June July August Sept. Oct. Nov. Dec. Jan.
2017
Feb. March
Oocysts 0/0 0/0 1/3 3/2 2/1 1/0 0/0 0/0 0/0 0/0 0/0 0/0
Volume
filtered
in liters
10/10 10/10.5 10/11.5 10/10 10/10.5 10/10 10/10 10.5/
10.5
10.5/10 10/10 10/10 10/10
Calculating Risk Bin Classification
Additional Crypto treatment required according to current
Crypto oocyst concentration:
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LT2 REQUIREMENTS - CA/NV
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CA/NV
Requirements of
the Rule
LT2 REQUIREMENTS - CA/NV
Reporting Results – Lab or System?
• All source water samples taken under the LT2 rule
must be reported to your respective state agency.
• The system or the laboratory may submit the source
water monitoring data to the state agency.
• The system will need to review and approve the source
water monitoring data before it is submitted to the
state.
• The PWS is ultimately responsible for making sure the
lab reports the monitoring data.
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LT2 REQUIREMENTS - CA/NV
Forms.
• EPA states that systems must report LT2 monitoring to
the state no later than 10 days after the end of the first
month following the month when the samples were
collected (e.g., a system that collects samples in
October 2015 must report that data no later than
December 10, 2015).
• Data must be reported monthly.
NV LT2 reporting – No electronic reporting. Will be
modifying current forms and process to accommodate
LT2.
CA LT2 reporting – Electronic reporting via State Write
On database. Modifying PWS IDs to be consistent with 29
Reporting Components
Cryptosporidium sample:
• PWS ID
• Facility ID
• Sample collection date
• Sample type (field or matrix spike)
• Sample volume filtered (L), to nearest ¼ L
• Was 100% of filtered volume examined, Y/N
• Number of oocysts counted
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Reporting Continued
E. coli samples:
• PWS ID
• Facility ID
• Sample collection date
• Analytical method number
• Method type
• Source type (flowing stream, lake/reservoir, GUDI)
• E. coli/100 mL
• Turbidity
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Reporting Continued
For matrix spike samples, systems must also report
the sample volume spiked and estimated number of
oocysts spiked.
• For samples in which less than 10 L is filtered or less than 100%
of sample volume is examined, systems must also report the
number of filters used and the packed pellet volume.
• For samples in which less than 100% of sample volume is
examined, systems must also report the volume of re-
suspended concentrate and volume of this re-suspension
processed through immunomagnetic separation.
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LT2 REQUIREMENTS - CA/NV
Sample Plans
• Sampling plans due dates are established by a
system’s schedule.
• Systems serving 100,000 or more sample the earliest
and are required to submit their sampling schedule to
the state by January 1, 2015, with sampling to begin
during the month of April 2015.
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LT2 REQUIREMENTS - CA/NV
Schedule 1-4
Population
Served
Sampling for SAMPLING PLAN
DUE to CA/NV
SAMPLING
TO BEGIN
1
100,000 or
more served
Cryptosporidium, E. coli,
turbidity-24 months
1-1-2015 4-1-2015
2
50,000 to
99,999 served
Cryptosporidium, E. coli,
turbidity-24 months
7-1-2015 10-1-2015
3
10,000 to
49,999 served
Cryptosporidium, E. coli,
turbidity-24 months
7-1-2016 10-1-2016
4
Less than
10,000 served
E. coli-12 months 7-1-2017 10-1-2017
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Sampling
Where do I collect my sample?
Systems must submit a description of their sampling
location to the State 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
Coordinate with your Laboratory
Crypto and E. Coli sample analysis must be performed
at EPA or State approved laboratories
Crypto samples must be sent to a lab certified by ELAP
for LT2 Crypto.
Receipt at lab within (generally) <24 hours (E Coli), <72
hours (Crypto) <20 degrees C, confirm laboratory
hours/days of operation (typically M-Th)
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Sampling
What equipment and instructions provided?
• Field filtering vs 10L Bulk Water Collection
• EnvirochekTM
• Envirochek HV CapsulesTM
• Filta-Max® Filter
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LT2 – Sample Collection
1. Flush (2-3 min) until turb/temp stable
2. Fill Cubitainer and Ship (after flush)
1. Connect Sample Unit without filter
2. Flush (2-3 min) until turb/temp stable
3. Install Filter
4. Open Tap, Bleed out air & adjust flow/pressure
5. Turn off after 10 liters
6. Remove outlet tubing and drain
7. Disconnect inlet tubing, seal capsule, bag, chill and ship
Lab FiltrationPotential for Additional Fees
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Sample Elution
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Centrifugation
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Centrifugation
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Pellet Size Potential for Additional Analytical Fees
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Vortex
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IMS
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IMS cont.
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IMS cont.
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IMS cont.
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Reading Slides
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Under the Microscope
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Multiple Cryptosporidium
Multiple Giardia
LT2 Round 1
• Scheduling
• Sample Collection
• Reporting and DCTS
• Quality Control
• Laboratory Attrition
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Scheduling - Round 1
• All schedules and sampling plans had to be approved
by EPA
• EPA understaffed and fell behind approvals quickly
• Scheduling guidance and training was unclear early
• Schedules were not agreed to by laboratories
• Many labs became over capacity
• Some PWS were without a lab
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Sample Collection – Round 1
• Sample temperature issues
• Bulk samples > 20 degrees C
• Filters frozen
• Missed matrix spikes
• Shipping of E. coli samples
• Missed collection dates
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Reporting & DCTS – Round 1
• Data Control and Tracking System (DCTS)
• All data entered manually in web forms
• Frequent crashes
• Very slow when operational
• Lab could not report results in oocysts/liter to client
• Created confusion for client
• Made bin calculation even more confusing
Quality Control – Round 1
• Matrix Spikes
• Average recoveries from 25 to 50%
• No recovery requirements
• High turbidity samples
• Some samples took 6-8 hours to read slides
• Matrix spike may have results of 0%
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Laboratory Attrition – Round 1
• 48 labs on EPA approved lab list
• Municipal labs
• State labs
• Commercial labs
• Several dropped out or were dropped
• Lost analysts
• Approval revoked
• Too few samples
• High materials cost
Resources & References
• LT2 Rule Cryptosporidium & E. coli Sample
Collection Recommendations Pocket Guide
http://water.epa.gov/lawsregs/rulesregs/sdwa/lt2/upload/epa817k06002.pd
f
• Parasites – Cryptosporidium
http://www.cdc.gov/parasites/crypto/
• Environmental Health Services (EHS) – Cryptosporidium,
Cryptosporidiosis
http://www.cdc.gov/nceh/ehs/topics/Cryptosporidium.htm
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Thank you
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Monica Van Natta
Account Manager
Eurofins Eaton Analytical
559-326-4396