Regulatory Review Presented by: Joe Munson

Outline

New Employee/Office

Lead and Copper Reminder

Stage 2 Disinfection Byproduct Rule

New Employee

Patty Krein is the new Drinking Water Secretary.

Drinking Water has a new office location in Sioux Falls. Phone: 362-3521.

Lead and Copper Reminder If your EPA ID# > 630. If you are scheduled to sample for Pb and Cu

every three years. Then you have until September 30 to collect

your Pb and Cu samples.

Stage 2 Disinfection Byproduct Rule (DBPR)

Will apply to all community and nontransient noncommunity water systems that add a chemical disinfectant or that purchase water with an added chemical disinfectant.

403 systems in South Dakota will have to comply with Stage 2 regulations.

Initial DistributionSystem Evaluation (IDSE)

Options

Very Small System Waiver (VSS) 40/30 Certification Standard Monitoring Plan (SM) System Specific Study (SSS)

IDSE Implementation Timeline

Sch.

Systems Serving:

Submit 40/30

Certification, SM, SSS Plan, or

receive VSS Waiver by:

Complete SM or SSS

By:

Submit IDSE Report (only

systems conducting SM or SSS)

by:

1 > 100,000 Oct. 1, 2006Sept. 30,

2008Jan. 1, 2009

2 50,000–99,999

Apr. 1, 2007Mar. 31,

2009July 1, 2009

3 10,000–49,999

Oct. 1, 2007Sept. 30,

2009Jan. 1, 2010

4 < 10,000 Apr. 1, 2008Mar. 31,

2010July 1, 2010

Schedule for systems in a combined distribution system is based on that of the largest system in the combined

distribution system

Very Small System (VSS) Waiver

Eligibility Criteria

• Systems must Serve fewer than 500 people Have taken TTHM and HAA5 samples

Reduced monitoring acceptable Operational data acceptable

• 137 systems out of an eligible 243 systems in South Dakota have received their VSS Waiver

Note: EPA or the state may deny a VSS Waiver for any reason, even if system meets

all eligibility criteria

VSS Waivers

• Waivers effective immediately− No application necessary− Systems must meet all criteria

• EPA or the state can require Standard Monitoring or System Specific Study

• VSS Waiver is only a waiver from additional IDSE activities− No Standard Monitoring or System Specific Study Plan− No IDSE Report

• Continue compliance with Stage 1 DBPR until Stage 2 DBPR compliance begins – Complete a monitoring plan for the Stage 2 DBPR

40/30 Certification

Eligibility Criteria

• Systems must have Stage 1 DBPR data or data equivalent to eight quarters worth of sampling:

− No individual sample can have exceeded:

0.040 mg/L for TTHM 0.030 mg/L for HAA5

− No TTHM or HAA5 monitoring violations

− For schedule 3 and 4 systems data can not be before January 1, 2005

• Approximately 88 systems in South Dakota will be eligible for a 40/30 Certification

Note: EPA or the state may deny the certification for any reason, even if system

meets all eligibility criteria

Operational Data

• EPA or the state may allow systems to use operational data to qualify for 40/30 certification.

Data must be equivalent to Stage 1 DBPR data. Samples must be taken and analyzed by

approved methods at a certified lab. Adequate number of sample sites for system

size. Samples must be taken at appropriate

locations (average or maximum residence times).

Samples must be taken at appropriate frequency and during the month of warmest water temperature.

Submitting a 40/30 Letter

• Once a system has collected a sufficient amount of data it can prepare a 40/30 Certification Letter and submit it to the EPA: Electronically (through EPA’s DCTS)

Hard-copy (through mail) US EPA-IPMC

PO Box 98 Dayton, OH 45401-0098

System InformationPWS Name_____________________ PWS ID:_______________________Street Address:__________________ City, State, Zip:_________________Population Served:_______________ Source Water Type: Ground

Subpart HSystem Type: CWS NTNCWSCombined Distribution System: Wholesale Consecutive Neither Contact PersonName: _______________________Title: ____________________Phone Number:__________________Fax Number (if available):____________Email Address (if available):_______________________CertificationI hereby certify that each individual Stage 1 DBPR compliance sample

collected from ________ to _______ was less than or equal to 0.040 mg/L for TTHM and 0.030 mg/L for HAA5. I understand that to be eligible, each individual sample must be equal to or below these values. I also certify that this PWS collected all required Stage 1 samples and did not have any monitoring violations during this time period.

Signature:_________________ Date:______________________

Example 40/30 Certification Letter

Standard Monitoring

Standard Monitoring Requirements

• Population served• Source water type• Justification of Standard Monitoring sites • Distribution system schematic

Entry points, sources, and storage facilities Locations and dates of proposed Standard

Monitoring sites Locations and dates of Stage 1 DBPR monitoring

sites

Standard Monitoring Requirements

• What, where, and how often do I monitor? Samples Collected

Dual sample set (both TTHM and HAA5) collected at all locations

Monitoring Locations High TTHM levels High HAA5 levels Average Residence Time Near Entry Points

Number of sites Based on system’s source water type and population

served Monitoring Frequency

1, 4, or 6 monitoring periods during the year at each location

Number based on population served and source type

TTHM and HAA5 Standard Monitoring(1)

• For groundwater systems or systems that purchase groundwater

PopulationFrequenc

y(in year)

Total

Sites

Near EP

ARTHigh TTHM

High HAA5

< 500 consecutive 1 (during peak

historical month)(2)

2 1 - 1 -

< 500 non-consecutive

2 - - 1 1

500-9,9994 (every 90 days)

2 - - 1 1

10,000 – 99,999 6 1 1 2 2

100,000-499,999 8 1 1 3 3

(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.

TTHM and HAA5 Standard Monitoring(1)

• For Subpart H systems and systems that purchase Subpart H water

Population Frequency Total Near EP ARTHigh TTHM

High HAA5

<500 consecutive 1 (during peak

historical month)(2)

2 1 - 1 -

<500 non-consecutive2 - - 1 1

500-3,300 consecutive

4 (every 90 days)

2 1 - 1 -

500-3,300 non-consecutive

2 - - 1 1

3,301-9,999 4 - 1 2 1

10,000-49,999 6 (every 60 days)

8 1 2 3 2

50,000- 249,999 16 3 4 5 4

Standard Monitoring Site Selection – Justification

• Plan must include a justification for the selection of sites to be sampled during Standard Monitoring

• Data sources and tools Distribution system maps Water quality data Distribution system operating data

Final “Selected” Sites

• Some site selection will be obvious Near entry point

• Others will require professional judgment Consider geographic representation Consider hydraulic representation Consider areas fed by sources with higher DBP

precursors Consider accessibility

Submitting Standard Monitoring Plan

• Once the system has collected and analyzed its information, it must prepare the plan and submit it to EPA.Electronically (through EPA’s

DCTS )Hard-copy (mail to IPMC address)

• Must include required information

System Specific Study (SSS)

Stage 2 Compliance Monitoring Schedule

Sch.SystemServing:

Start Stage 2 Compliance Monitoring By:

1 > 100,000 April 1, 2010

2 50,000 –99,999 Oct. 1, 2012

3 10,000 –49,999 Oct. 1, 2013

4 < 10,000Oct 1, 2013

Oct 1, 2014*

* Date for systems that were required to conduct Crypto monitoring under LT2

Questions?