# Presentation: 828100

## If you do not have a copy of the Stage 1 DBPR handouts, a copy can be downloaded from the Encounter Collaborative meeting page:https://ei.e2c.com/enc/enc-pc.pmtg 

## Stage 1 Disinfectants & Disinfection Byproducts Rule

**U.S. EPA **
**Webcast Training Session **
**April 27, 2005**

## Poll: Are you responsible for implementing Stage 1 DBPR?

- [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]
- Yes
- No
- Not applicable

## Why Stage 1 DBPR? Why Now?

- Stage 1
- Training for . . .

- EPA Oversight
- Visits Identified
- Problems with . . .

**Notes:**
From TCR Web cast 1:
The TCR has been in effect for over 15 years and it’s remained essentially unchanged, so you might be asking, “Why TCR training, why now?” 

States identified TCR as a training priority.  Guided by input from States, we developed our trainings for several audiences:
Recent hires with little TCR experience 
Veteran Drinking water staff who are new to the TCR
Veteran TCR managers who’d like a refresher on the federal rule

Also, EPA conducts “Data Verifications”, which are oversight visits to states.  During these visits, we’ve found misunderstandings and misinterpretations of the TCR even by veteran TCR staff so we realized it was time for us to offer a refresher.  EPA found problems with:
Routine and repeat monitoring frequencies, (esp the month after a positive routine sample)
Compliance calculations for MCL violations and data management for accurate calculations, and
Understanding where states do and do not have latitude in implementing the rule.

About that last point, it’s important to note that several states have adopted the federal total coliform rule with no changes.  But other states have adopted versions that are different from the federal rule.  In any case, these state rules should be no less stringent than the federal requirements we’re describing today.  

## Why Stage 1 DBPR? Why Now?

- Stage 1
- Training for . . .

- EPA Oversight
- Visits Identified
- Problems with . . .

- Calculating Compliance

- Routine, Reduced, and Increased Monitoring

- Understanding TOC Requirements

**Notes:**
From TCR Web cast 1:
The TCR has been in effect for over 15 years and it’s remained essentially unchanged, so you might be asking, “Why TCR training, why now?” 

States identified TCR as a training priority.  Guided by input from States, we developed our trainings for several audiences:
Recent hires with little TCR experience 
Veteran Drinking water staff who are new to the TCR
Veteran TCR managers who’d like a refresher on the federal rule

Also, EPA conducts “Data Verifications”, which are oversight visits to states.  During these visits, we’ve found misunderstandings and misinterpretations of the TCR even by veteran TCR staff so we realized it was time for us to offer a refresher.  EPA found problems with:
Routine and repeat monitoring frequencies, (esp the month after a positive routine sample)
Compliance calculations for MCL violations and data management for accurate calculations, and
Understanding where states do and do not have latitude in implementing the rule.

About that last point, it’s important to note that several states have adopted the federal total coliform rule with no changes.  But other states have adopted versions that are different from the federal rule.  In any case, these state rules should be no less stringent than the federal requirements we’re describing today.  

## Stage 1 DBPR Purpose and Scope

**Purpose:**  Increase public protection from disinfection by products (DBPs) by reducing the exposure to TTHMs, HAA5, bromate, and chlorite.
**Scope:**
- Applies to all public water systems that add a chemical disinfectant
- Except for transient systems that add a disinfectant other than chlorine dioxide
- Addresses both acute and non-acute health effects

## A Delicate Balance

**Risk:** microbial contamination vs. DBP formation
**U.S. EPA’s solution:** control health risks from microbials, disinfectants, and DBPs
**Result:** M-DBP suite of rules

**Microbials**

**Byproducts**

**Notes:**
One of the most complex questions facing systems is how to reduce risks from disinfectants and DBPs while providing sufficient protection against microbial contaminants.  

The 1996 SDWA Amendments require U.S. EPA to develop regulations to control microbial pathogens while minimizing the public health risk from disinfectants and DBPs in drinking water.  It is important to strengthen protection against microbial contaminants while at the same time reducing potential health risks from DBPs.

The Stage 1 DBPR, the IESWTR, and the LT1ESWTR are some of the rules promulgated by U.S. EPA under the 1996 SDWA Amendments.  These regulations are just a few in the group of regulations often referred to as the M-DBP Suite.  Other rules in this group include the TCR, the SWTR, the Filter Backwash and Recycling Rule, the GWR, and the proposed Stage 2 DBPR and LT2SWTR.

## Outline 

- Compliance & Reporting – TTHM, HAA5, Chlorine, Chloramines

- Overview

- Case Studies

- Monitoring – TTHM, HAA5, Chlorine, Chloramines

- DBP Precursors (DBPP)

- Q & A

- Question and answer sections through out the presentation

## Presenters

- Maria Lopez, U.S. EPA
- Rudd Coffey, The Cadmus Group, Inc.
- Ed Moriarty, U.S. EPA

- Tom Grubbs, U.S. EPA
- Katie Porter, U.S. EPA

- Panelists

- Overview

## 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

## Overview

**Review the Stage 1 DBPR requirements**

## Acronyms and Definitions

- A list of acronyms and definitions for the terms used in this presentation can be found in the handouts

- Overview

**Notes:**
“ART” is the location of average residence time, or the average water age that is delivered to customers.  There are a number of ways to calculate average residence time, and states may dictate which method to use.

“Best available technology” or “BAT” means the best technology, treatment techniques, or other means which the Administrator finds, after examination for efficacy under field conditions and not solely under laboratory conditions, are available (taking cost into consideration). 

A “CCR” is a Consumer Confidence Report, or the annual water quality report that community water systems are required to prepare and submit to consumers.

A “CWS” or community water system means a public water system that serves at least 15 service connections used by year-round residents or regularly serves at least 25 year-round residents. 

“DBPs” are compounds formed by the reaction of disinfectants with materials in the water supply.  These byproducts (such as trihalomethanes) can be harmful. 

“DBP Precursors” are the precursors in water (e.g., organic material, bromide) that combine with some disinfectants to produce DBPs. 

## Public Health & Disinfectants

**Disinfectants:**
- Kill disease-causing microorganisms
- React with substances naturally found in water to form harmful DBPs
- Produce negative health effects when present in excessive levels

- Overview

**Notes:**
Chlorination of drinking water was first used in Great Britain in the early 20th century, sharply reducing the occurrence of waterborne diseases.  Jersey City, NJ, was the first American city to use chlorine to disinfect their water in 1908, and many other cities soon followed suit.  Disinfection of drinking water is considered one of the major public health advances of the 20th century.  One hundred years ago, typhoid and cholera epidemics were common throughout American cities.  Disinfection of drinking water was a major factor in reducing these epidemics.

While disinfectants are effective in controlling many harmful microorganisms, they react with organic and inorganic matter in water to form DBPs.  

Toxicological studies show that some DBPs may be carcinogenic in laboratory animals.  Other DBPs have also been shown to cause adverse reproductive or developmental effects in laboratory animals.  Several epidemiological studies suggest a weak association between certain cancers or reproductive and developmental effects and exposure to chlorinated water.  

Disinfectants themselves may cause health problems if people are exposed to high levels over long periods of time.  These health problems include neurological damage to the nervous system and damage to the blood and kidneys.  More than 200 million people in this country consume water that is disinfected.  Because of the large population exposed, potential health risks associated with DBPs and disinfectants need to be taken seriously.

## Public Health & Disinfectants

**Disinfectants:**
- Kill disease-causing microorganisms
- React with substances naturally found in water to form harmful DBPs
- Produce negative health effects when present in excessive levels

**In excess amounts:**
- Eye and nose irritation
- Stomach discomfort
- Anemia
- Other acute short-term health effects

- Overview

**Notes:**
Chlorination of drinking water was first used in Great Britain in the early 20th century, sharply reducing the occurrence of waterborne diseases.  Jersey City, NJ, was the first American city to use chlorine to disinfect their water in 1908, and many other cities soon followed suit.  Disinfection of drinking water is considered one of the major public health advances of the 20th century.  One hundred years ago, typhoid and cholera epidemics were common throughout American cities.  Disinfection of drinking water was a major factor in reducing these epidemics.

While disinfectants are effective in controlling many harmful microorganisms, they react with organic and inorganic matter in water to form DBPs.  

Toxicological studies show that some DBPs may be carcinogenic in laboratory animals.  Other DBPs have also been shown to cause adverse reproductive or developmental effects in laboratory animals.  Several epidemiological studies suggest a weak association between certain cancers or reproductive and developmental effects and exposure to chlorinated water.  

Disinfectants themselves may cause health problems if people are exposed to high levels over long periods of time.  These health problems include neurological damage to the nervous system and damage to the blood and kidneys.  More than 200 million people in this country consume water that is disinfected.  Because of the large population exposed, potential health risks associated with DBPs and disinfectants need to be taken seriously.

## How Are DBPs Formed?

**NOM**
**Bromide**

**+**

- Overview

**Notes:**
DBP formation is influenced by several factors, including precursor concentrations and water temperature.  For instance, DBPs formed from organic material are produced at a higher rate as the temperature of the water increases.  This usually leads to higher disinfectant demand and higher TTHM and HAA5 concentrations during summer months and in warmer climates.  

Different disinfectants form different byproducts.  Chlorine and chloramines react with NOM to form TTHM and HAA5.  Using ozone to disinfect (or oxidize) water containing bromide ions can form the byproduct bromate.  Chlorine dioxide is unstable in water and rapidly dissociates into chlorite when mixed with NOM.

These disinfectants can react to form DBPs even if they are added to oxidize materials in water rather than to disinfect.  Therefore, systems that use these chemicals for disinfection or oxidation must comply with the applicable standards.

## How Are DBPs Formed?

**NOM**
**Bromide**

**Added Disinfectant**

**Chlorine **
**Ozone**
**Chloramines**
**Chlorine Dioxide**

**+**

**=**

- Overview

**Notes:**
DBP formation is influenced by several factors, including precursor concentrations and water temperature.  For instance, DBPs formed from organic material are produced at a higher rate as the temperature of the water increases.  This usually leads to higher disinfectant demand and higher TTHM and HAA5 concentrations during summer months and in warmer climates.  

Different disinfectants form different byproducts.  Chlorine and chloramines react with NOM to form TTHM and HAA5.  Using ozone to disinfect (or oxidize) water containing bromide ions can form the byproduct bromate.  Chlorine dioxide is unstable in water and rapidly dissociates into chlorite when mixed with NOM.

These disinfectants can react to form DBPs even if they are added to oxidize materials in water rather than to disinfect.  Therefore, systems that use these chemicals for disinfection or oxidation must comply with the applicable standards.

## How Are DBPs Formed?

**NOM**
**Bromide**

**Added Disinfectant**

**Chlorine **
**Ozone**
**Chloramines**
**Chlorine Dioxide**

**TTHM**
**HAA5**
**Bromate**
**Chlorite**

**DBPs**

**+**

**=**

- Overview

**Notes:**
DBP formation is influenced by several factors, including precursor concentrations and water temperature.  For instance, DBPs formed from organic material are produced at a higher rate as the temperature of the water increases.  This usually leads to higher disinfectant demand and higher TTHM and HAA5 concentrations during summer months and in warmer climates.  

Different disinfectants form different byproducts.  Chlorine and chloramines react with NOM to form TTHM and HAA5.  Using ozone to disinfect (or oxidize) water containing bromide ions can form the byproduct bromate.  Chlorine dioxide is unstable in water and rapidly dissociates into chlorite when mixed with NOM.

These disinfectants can react to form DBPs even if they are added to oxidize materials in water rather than to disinfect.  Therefore, systems that use these chemicals for disinfection or oxidation must comply with the applicable standards.

## How Are DBPs Formed?

**NOM**
**Bromide**

**Added Disinfectant**

**Chlorine **
**Ozone**
**Chloramines**
**Chlorine Dioxide**

**Health Effects: **
- Some DBPs may cause adverse reproductive or development effects:
- Low birth weight
- Early term miscarriage
- Some studies suggest a connection between chlorinated water and:
- Bladder, rectal, and colon cancer

**TTHM**
**HAA5**
**Bromate**
**Chlorite**

**DBPs**

**+**

**=**

- Overview

**Notes:**
DBP formation is influenced by several factors, including precursor concentrations and water temperature.  For instance, DBPs formed from organic material are produced at a higher rate as the temperature of the water increases.  This usually leads to higher disinfectant demand and higher TTHM and HAA5 concentrations during summer months and in warmer climates.  

Different disinfectants form different byproducts.  Chlorine and chloramines react with NOM to form TTHM and HAA5.  Using ozone to disinfect (or oxidize) water containing bromide ions can form the byproduct bromate.  Chlorine dioxide is unstable in water and rapidly dissociates into chlorite when mixed with NOM.

These disinfectants can react to form DBPs even if they are added to oxidize materials in water rather than to disinfect.  Therefore, systems that use these chemicals for disinfection or oxidation must comply with the applicable standards.

## MRDL & MCL Overview

**Maximum Residual Disinfectant Levels (MRDLs) **

| Disinfectant | MRDL |
| --- | --- |
| Chlorine | 4.0 mg/L |
| Chloramines | 4.0 mg/L |
| Chlorine Dioxide | 0.8 mg/L |

- Overview

| Disinfection Byproduct | MCL |
| --- | --- |
| TTHM | 0.080 mg/L |
| HAA5 | 0.060 mg/L |
| Bromate | 0.010 mg/L |
| Chlorite | 1.0 mg/L |

**Maximum Contaminant Levels (MCLs) **

**Notes:**
The Stage 1 DBPR establishes MRDLs for chlorine, chloramines, and chlorine dioxide. These standards apply to all CWSs and NTNCWSs that add a chemical disinfectant for either primary or residual treatment.  The chlorine dioxide MRDL also applies to TNCWSs, due to the acute health effects of chlorine dioxide.

Presenter:  Mention Ozone during the training.
The Stage 1 DBPR builds on the 1979 standard by tightening the MCL for TTHM and widening the range of affected systems to include all CWSs and NTNCWSs that add a disinfectant.  The Stage 1 DBPR focuses on minimizing the formation of DBPs in distribution systems to reduce the long-term exposure of customers to these potentially harmful compounds. The Stage 1 DBPR also establishes MCLs for chlorite, bromate, and HAA5. 

## TOC Removal Overview

- New treatment technique regulations for Total Organic Carbon (TOC)
- Based on source water characteristics, systems must remove specified quantities of TOC.
- Systems can comply through TOC removal or through alternative compliance criteria.

- Overview

**Notes:**
The Stage 1 DBPR requires Subpart H systems practicing conventional filtration to remove specified percentages of organic material (DBP precursors), measured as TOC, that react with disinfectants to form DBPs.

## Monitoring Plans

- Each system must develop and implement a monitoring plan
- Plan must include:
- Sample location and schedules
- Representative of entire distribution system
- Compliance calculation methodology
- Plans must have been available for state inspection by January 2004.
- Subpart H systems serving > 3,300 must have submitted monitoring plans to the state by April 2004

- Overview

**Notes:**
Each system required to monitor under the Stage 1 DBPR must develop and implement a monitoring plan that details how it will meet all applicable regulations.  

The monitoring plan must include the following elements:
 Specific locations and schedules for collecting samples; and,
 How the system will calculate compliance with MCLs, MRDLs, and removal requirements.  

If approved for monitoring as a consecutive system, or if providing water to a consecutive system, the monitoring plan must reflect the entire distribution system.

For more information on monitoring plans, see 40 CFR 141.132(f).  States may have guidances available to assist in developing the monitoring plan.  In addition, states may have specific forms or requirements for monitoring plan. 

Systems must maintain their monitoring plan and make it available for inspection by the state and the general public.  All Subpart H systems serving between 3,300 and 10,000 people must have submitted a copy of their monitoring plan to the state by April 10, 2004.  States may require systems to submit their monitoring plans. 

## Analytical Methods

- Stage 1 DBPR specifies analytical methods for each standard
- Only certified labs can analyze MCL samples
- Exception: daily chlorite samples
- For daily chlorite, disinfectants, and all other non-MCL parameters (e.g., alkalinity, TOC, bromide), analysis may be conducted by a party approved by U.S. EPA or the state

- Overview

**Notes:**
The Stage 1 DBPR specifies analytical methods for measuring each relevant water quality parameter, disinfectant, contaminant, and DBP precursors.  Consistent with current regulations, only certified laboratories can analyze samples for compliance with the MCLs (with the exception of the daily measurement of chlorite at the entrance to the distribution system).  

U.S. EPA believes that daily chlorite samples, all disinfectant samples (chlorine, chloramines, and chlorine dioxide), and TOC may deteriorate before reaching a certified laboratory.  U.S. EPA also believes that samples for these substances, as well as alkalinity and bromide, can be adequately analyzed on-site.  For these reasons, U.S. EPA allows analysis of the samples by a party approved by EPA or the state.  For more information on analytical methods, see 40 CFR 141.30 and 40 CFR 141.131.

## Applicability to Systems

- This presentation covers:
- TTHM, HAA5, chlorine, and chloramines
- Some compliance options for TOC Removal
- This training does not focus on:
- Requirements for systems disinfecting with ozone or chlorine dioxide

- Overview

## Poll: How long have you worked with the Stage 1 DBPR?

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- 0-6 Months
- 7-12 Months
- 1-2 Years
- 2-4 Years
- 4+ Years

## Questions

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

- Q & A

## Monitoring Overview

**Chlorine & Chloramines**
**TTHM & HAA5**

## General Sampling

- When sampling remember to:
- Only take samples under normal operating conditions
- Sample according to the monitoring plan
- Only sample when serving the public

- Monitoring

## Chlorine & Chloramines Monitoring

- Chlorine and chloramines monitoring based on TCR monitoring.
- Systems must monitor for chlorine and chloramines every time they sample for total coliform
- Includes repeat total coliform-positive monitoring & reduced TCR monitoring
- Must be taken at same location as TCR samples
- No reduced monitoring

**1 TCR sample **
**=**
**1 chlorine or chloramines sample**

- Monitoring

**Notes:**
Under the Stage 1 Disinfectants and Disinfection Byproducts Rule (Stage 1 DBPR), there is no requirement to increase monitoring for chlorine and chloramines as a result of a violation or exceedance of the MRDL.  However, systems will have to collect additional chlorine and chloramines samples (at the same time and location) if they are required under the TCR to take repeat total coliform samples following a total coliform-positive result.  Likewise, reduced monitoring for chlorine and chloramines is technically not permitted under the Stage 1 DBPR.  However, reduced TCR monitoring for systems serving 25 to 1,000 persons affects the frequency of chlorine and chloramines monitoring.  If a system reduces its TCR monitoring, it is allowed to also reduce its monitoring for chlorine and chloramines (at the same time and location) to match. 

Failure to monitor is treated as a monitoring violation for the entire 1-year period for which compliance with the MRDL cannot be determined.

## TTHM & HAA5 Monitoring

| Type of System | Monitoring Frequency | Locations |
| --- | --- | --- |
| Subpart H serving > 10,000 | 4 samples per plant per quarter | At least 25% at MRT
Remaining samples at ART |

- MRT = Maximum Residence Time
- ART = Average Residence Time

- Monitoring

**Notes:**
For more information on TTHM and HAA5 monitoring requirements, see 40 CFR 141.132(b).

## TTHM & HAA5 Monitoring

| Type of System | Monitoring Frequency | Locations |
| --- | --- | --- |
| Subpart H serving > 10,000 | 4 samples per plant per quarter | At least 25% at MRT
Remaining samples at ART |
| Subpart H serving 500 – 9,999 | 1 sample per plant per quarter | MRT |
| GW serving > 10,000 |  |  |

- Monitoring

**Notes:**
For more information on TTHM and HAA5 monitoring requirements, see 40 CFR 141.132(b).

## TTHM & HAA5 Monitoring

| Type of System | Monitoring Frequency | Locations |
| --- | --- | --- |
| Subpart H serving > 10,000 | 4 samples per plant per quarter | At least 25% at MRT
Remaining samples at ART |
| Subpart H serving 500 – 9,999 | 1 sample per plant per quarter | MRT |
| GW serving > 10,000 |  |  |
| Subpart H serving < 500 | 1 sample per plant per year during month of warmest water temperature | MRT |
| GW serving < 10,000 |  | MRT |

- Monitoring

**Notes:**
For more information on TTHM and HAA5 monitoring requirements, see 40 CFR 141.132(b).

## TTHM & HAA5 Reduced Monitoring

| Type of System | Requirement | Reduced Level |
| --- | --- | --- |
| Subpart H serving > 10,000 | TTHM RAA < 0.040 mg/L
HAA5 RAA < 0.030 mg/L

Source Water TOC RAA < 4.0 mg/L (subpart H only) | 1 sample per plant per quarter at MRT |
| Subpart H serving 
500 – 9,999 |  | 1 sample per plant per year during month of warmest water temperature |
| GW serving > 10,000 |  |  |

- Monitoring

## TTHM & HAA5 Reduced Monitoring

| Type of System | Requirement | Reduced Level |
| --- | --- | --- |
| Subpart H serving > 10,000 | TTHM RAA < 0.040 mg/L
HAA5 RAA < 0.030 mg/L

Source Water TOC RAA < 4.0 mg/L (subpart H only) | 1 sample per plant per quarter at MRT |
| Subpart H serving 
500 – 9,999 |  | 1 sample per plant per year during month of warmest water temperature |
| GW serving > 10,000 |  |  |
| Subpart H serving < 500 | N/A | N/A |

- Monitoring

## TTHM & HAA5 Reduced Monitoring

| Type of System | Requirement | Reduced Level |
| --- | --- | --- |
| Subpart H serving > 10,000 | TTHM RAA < 0.040 mg/L
HAA5 RAA < 0.030 mg/L

Source Water TOC RAA < 4.0 mg/L (subpart H only) | 1 sample per plant per quarter at MRT |
| Subpart H serving 
500 – 9,999 |  | 1 sample per plant per year during month of warmest water temperature |
| GW serving > 10,000 |  |  |
| Subpart H serving < 500 | N/A | N/A |
| GW serving < 10,000 | TTHM RAA < 0.040 mg/L
HAA5 RAA < 0.030 mg/L
For 2 years or
TTHM RAA < 0.020 mg/L
HAA5 RAA < 0.015 mg/L
For 1 year | 1 sample per treatment plant per 3-year monitoring cycle at MRT |

- Monitoring

## TTHM & HAA5 Increased Monitoring

| Type of System | Trigger | Increased Level |
| --- | --- | --- |
| Subpart H serving > 10,000 | N/A | N/A |
| Subpart H serving 500 – 9,999 |  |  |
| GW serving > 10,000 |  |  |

- Monitoring

## TTHM & HAA5 Increased Monitoring

| Type of System | Trigger | Increased Level |
| --- | --- | --- |
| Subpart H serving > 10,000 | N/A | N/A |
| Subpart H serving 500 – 9,999 |  |  |
| GW serving > 10,000 |  |  |
| Subpart H serving < 500 | Any TTHM or HAA5 result > MCL | 1 sample per treatment plant per quarter at MRT |
| GW serving < 10,000 |  |  |

- Monitoring

## Quiz #1:PWS Takes 1 Routine TCR Sample/Month

- One routine TCR sample
- Adds chlorine for disinfection
- Ground water system

- What does this system need to do to comply with the Stage 1 DBPR chlorine monitoring requirements?

- Monitoring

## Quiz #1:PWS Takes 1 Routine TCR Sample/Month

- One routine TCR sample
- Adds chlorine for disinfection
- Ground water system

- What does this system need to do to comply with the Stage 1 DBPR chlorine monitoring requirements?

**System needs to take 1 chlorine sample at the same time and place as the TCR sample**

- Monitoring

## Quiz #2:PWS Takes 3 Routine TCR Samples/Month

- Three routine TC samples
- One TC+ sample
- Adds chloramines for disinfection
- Ground water system

- What does this system need to do to comply with the Stage 1 DBPR chloramines monitoring requirements?

- Monitoring

## Quiz #2:PWS Takes 3 Routine TCR Samples/Month

- Three routine TC samples
- One TC+ sample
- Adds chloramines for disinfection
- Ground water system

- What does this system need to do to comply with the Stage 1 DBPR chloramines monitoring requirements?

- System needs to take 3 chloramines samples at the same time and place as the initial TCR samples.
- System needs to take 3 chloramines sample at the same time and place as 3 TCR repeat samples.
- System needs to take 5 repeat TCR and chloramines samples the following month.

- Monitoring

## Quiz #3:PWS on Routine TTHM & HAA5 Sampling

- RAAs
- TTHM = 0.035 mg/L
- HAA5 = 0.020 mg/L
- GWUDI system serving 9,000 persons

- What does this system need to do to comply with the Stage 1 DBPR TTHM and HAA5 monitoring requirement?

- Monitoring

## Quiz #3:PWS on Routine TTHM & HAA5 Sampling

- RAAs
- TTHM = 0.035 mg/L
- HAA5 = 0.020 mg/L
- GWUDI system serving 9,000 persons

- What does this system need to do to comply with the Stage 1 DBPR TTHM and HAA5 monitoring requirement?

**If the system stays on routine monitoring it must take 1 sample per plant per quarter.  Because the system’s RAA are ****< 0.040 mg/L for TTHMs and < 0.030 mg/L for HAA5, the system may qualify for reduced monitoring of ****one sample a year during the month of warmest water temperature.  They would need to consult with their state. **

- Monitoring

**Notes:**
To qualify for reduced, the system will need to take a TOC sample because it is a subpart H system.

## Questions

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

- Q & A

## Compliance and Reporting

**Chlorine & Chloramines **
**TTHM & HAA5**

## General Compliance Calculation

- When calculating compliance remember to:
- Compare the running annual average (RAA) of the results from last 12 months to standard
- Include all sampling results (unless designated as operational samples in monitoring plans)
- Calculate compliance at the end of every quarter in which system monitors
- State can calculate compliance

- Compliance and Reporting

**Notes:**
 12 months, not calendar year
 systems may take more than minimum number required, but these additional samples should be in the system’s monitoring plan so that the state can make sure the system is not trying to sample out of a violation
 every quarter the system monitored or was supposed to monitor
 if the system missed one or more samples in a quarter, it does not get to assume the value of the missed sample is zero

## Chlorine & Chloramines: Compliance Calculation

- Based on RAA of monthly results or averages
- Calculated each quarter the system serves water to the public
- Any RAA that exceeds the MRDL is a violation

- Compliance and Reporting

**Notes:**
 Monthly average if there is more than 1 result per month

 Calculated each quarter the system monitors or is supposed to monitor

 Okay if RAA is exactly equal to the MRDL

## TTHM & HAA5:Quarterly Compliance Calculation

- Based on RAA of quarterly results or averages
- Calculated each quarter the system serves water to the public
- Any RAA that exceeds the MCL is a violation

- Compliance and Reporting

**Notes:**
Calculated each quarter the system operates, even if they did not monitor

## TTHM & HAA5:Annual/Triennial Compliance Calculation

- If sample result > MCL:
- Not yet in violation of MCL unless sample result is > 4 times MCL
- Must move to increased monitoring schedule
- If on reduced monitoring and sample > 75% of MCL:
- Must return to routine monitoring schedule

- Compliance and Reporting

**Notes:**
Must return to quarterly monitoring if on reduced and sample exceeds 75%

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 1: Determine number of samples required

- Subpart H system serving 500-9,999 on routine monitoring

- Compliance and Reporting

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 1: Determine number of samples required
- 2. Calculate RAA to determine compliance

**TTHM sample 3****rd**** quarter of 2005**
**3Q 2005: 0.070 mg/L**
**2Q 2005: 0.080 mg/L**
**1Q 2005: 0.080 mg/L **
**4Q 2004: 0.090 mg/L**

**The system is required to take 1 sample per treatment plant per quarter**

- Subpart H system serving 500-9,999 on routine monitoring

- Compliance and Reporting

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 2. Calculate the RAA for TTHM

**Example: **
**Sum of quarterly averages = (0.090 + 0.080 + 0.080 + 0.070) = 0.320 mg/L**

**Use these results to calculate an RAA**

- Compliance and Reporting

- Subpart H system serving 500-9,999 on routine monitoring

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 2. Calculate the RAA for TTHM

**Example: **
**Sum of quarterly averages = (0.090 + 0.080 + 0.080 + 0.070) = 0.320 mg/L**

**Sum of quarterly averages = 0.320 mg/L**
**RAA = 0.320/4**
**RAA = 0.080 mg/L **_**<**_** MCL**

**Use these results to calculate an RAA**

- Compliance and Reporting

- Subpart H system serving 500-9,999 on routine monitoring

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 2. Calculate the RAA for TTHM

**Example: **
**Sum of quarterly averages = (0.090 + 0.080 + 0.080 + 0.070) = 0.320 mg/L**

**Sum of quarterly averages = 0.320 mg/L**
**RAA = 0.320/4**
**RAA = 0.080 mg/L **_**<**_** MCL**

**Use these results to calculate an RAA**

**System is in compliance!**

- Compliance and Reporting

- Subpart H system serving 500-9,999 on routine monitoring

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 1: Determine number of samples required

- GW system serving > 10,000 on routine monitoring

- Compliance and Reporting

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 1: Determine number of samples required

**The system is required to take 1 sample per treatment plant per quarter**

| Date | Avg. of all samples |
| --- | --- |
| Q1: Jan 2004 | 0.057 |
| Q2: April 2004 | 0.029 |
| Q3: July 2004 | 0.064 |
| Q4: Nov 2004 | 0.081 |
| Q1: Jan 2005 | 0.037 |

- GW system serving > 10,000 on routine monitoring

- Compliance and Reporting

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 2. Which samples should the system use for calculating compliance for Q1 2005?

- Compliance and Reporting

- GW system serving > 10,000 on routine monitoring

| Date | Avg. of all samples |
| --- | --- |
| Q1: Jan 2004 | 0.057 |
| Q2: April 2004 | 0.029 |
| Q3: July 2004 | 0.064 |
| Q4: Nov 2004 | 0.081 |
| Q1: Jan 2005 | 0.037 |

**Identify results to calculate HAA5 RAA**

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 2. Which samples should the system use for calculating compliance for Q1 2005?

- Compliance and Reporting

| Date | Avg. of all samples |
| --- | --- |
| Q1: Jan 2004 | 0.057 |
| Q2: April 2004 | 0.029 |
| Q3: July 2004 | 0.064 |
| Q4: Nov 2004 | 0.081 |
| Q1: Jan 2005 | 0.037 |

**Identify results to calculate HAA5 RAA**

- GW system serving > 10,000 on routine monitoring

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 2. Calculate the RAA for HAA5

**Example: **
**Sum of quarterly averages = (0.029 + 0.064 + 0.081 + 0.037) = 0.211 mg/L**

**Use these results to calculate an RAA**

- Compliance and Reporting

- GW system serving > 10,000 on routine monitoring

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 2. Calculate the RAA for HAA5

**Example: **
**Sum of quarterly averages = (0.029 + 0.064 + 0.081 + 0.037) = 0.211 mg/L**

**Sum of quarterly averages = 0.211 mg/L**
**RAA = 0. 211/4**
**RAA = 0.053 mg/L **_**<**_** MCL**

**Use these results to calculate an RAA**

- Compliance and Reporting

- GW system serving > 10,000 on routine monitoring

## Quiz#4: Calculating Compliance for TTHM & HAA5

- 2. Calculate the RAA for HAA5

**Example: **
**Sum of quarterly averages = (0.029 + 0.064 + 0.081 + 0.037) = 0.211 mg/L**

**Sum of quarterly averages = 0.211 mg/L**
**RAA = 0. 211/4**
**RAA = 0.053 mg/L **_**<**_** MCL**

**Use these results to calculate an RAA**

- Compliance and Reporting

**System is in compliance!**

- GW system serving > 10,000 on routine monitoring

## Chlorine & Chloramines Reporting

- Number of samples taken during each month of the last quarter

- Monthly arithmetic average of all samples taken in each month for the last 12 months

- Arithmetic average of the monthly averages for the last 12 months

- MRDL violations

- Compliance and Reporting

## TTHM & HAA5 Reporting

- Location, date and result of each sample taken during the last quarter

- Arithmetic average of all the samples taken in the last quarter

- Annual arithmetic average of the quarterly averages of the last 4 quarters

- MCL violations

- Compliance and Reporting

- Report to State due within 10 days of the end of each quarter.    		Remember to include:

## PN Rule Requirements

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

**If a system commits a monitoring violation, it must inform the state and its customers **

- Compliance and Reporting

**Notes:**
If a system violates the MCL for TTHM or HAA5, it must report the violation to the state within 48 hours (40 CFR 141.31(b)).  TTHM or HAA5 MCL violations require Tier 2 public notice as soon as practical but no later than 30 days after the system learns of the violation.  Public notifications (PN) must include the specific health effects language for TTHM and HAA5 from Appendix B of Subpart Q of 40 CFR 141:

TTHM: “Some people who drink water containing trihalomethanes in excess of the MCL over many years may experience problems with their liver, kidneys, or central nervous system, and may have an increased risk of getting cancer.”

HAA5: “Some people who drink water containing haloacetic acids in excess of the MCL over many years may have an increased risk of getting cancer.”

Systems must provide notice to each customer receiving a bill, to other service connections to which water is delivered by the system, and to other people regularly served by the system who would not be otherwise notified (e.g., house renters, students, nursing home patients, prison inmates).  There are a variety of ways to distribute violation notices to the public: door-to-door delivery; direct mail; public postings; and newspaper or radio announcements.  Systems must confirm that all PN requirements have been met and include a copy of the PN in a letter to the state within 10 days of notifying their customers.

If a system fails to prepare and/or submit a monitoring plan or monitor according to its monitoring plan, it has committed a monitoring violation.  If its failure to monitor makes it impossible to determine compliance with the MCLs, it has also committed an MCL violation.  For example, failure to sample for TTHM or HAA5 during four consecutive quarters is an MCL violation. 

All monitoring violations must be reported to the state and to customers.  Generally, monitoring violations require Tier 3 public notice; that is, the public must be notified within 12 months of learning of the violation.  Systems may include the notification in their Consumer Confidence Report (CCR) if it is published in time to satisfy the 12-month deadline.  However, states have the discretion to impose more stringent PN requirements.

Please note: for systems using chlorine dioxide, requirements are different, contact your state for details of these requirements. 

## Returning to Compliance

- Options for systems with compliance problems:
- BATs
- Source water changes
- Partnership with other system(s)
- Modify treatment

- Compliance and Reporting

**Notes:**
If a system is having difficulty complying with the MCLs, there are several options to consider to return to compliance. EPA has specified best available technologies (BATs) for the TTHM and HAA5 MCLs.  These BATs are effective in controlling chemicals in drinking water and are affordable for systems.  The EPA-specified BATs for TTHM and HAA5 are enhanced coagulation, enhanced softening, or granular activated carbon (GAC 10), with chlorine as the primary and residual disinfectant.  For more information on BATs for TTHM and HAA5, see 40 CFR 141.64(c).

Systems might also want to consider new source water options.  If raw water NOM levels are high, blending raw water with water from a source with lower NOM levels might be an option.  Abandoning an existing source is also an option, though it can be expensive and may present new problems, like compliance with other regulations.  If microbial problems stem from poor quality source water, increased source water protection efforts may resolve the issue.  Protecting source water may help reduce microbial problems and thus disinfectant levels required to inactivate microbials.

If water quality continues to be a problem, partnerships with another system might help resolve the problem.  Partnerships can take the form of joining with one or more communities to form a consolidated system or purchasing water from another established system.

Replacing disinfection or oxidation methods may also help return to compliance.  Some options include decreasing contact time and/or the concentration of the disinfectant, adjusting the pH, or changing disinfectants.  Chloramines generally produce fewer byproducts than chlorine.  Systems using chlorine may want to consider using chloramines instead (especially for secondary disinfection).  Other alternatives include combining disinfectants, potassium permanganate, peroxone, or UV radiation.  When considering a change in disinfection or oxidation methods, systems should be aware that the Surface Water Treatment Rule requires Subpart H systems to achieve at least the same level of microbial removal it is currently achieving if it changes its disinfection practices (part of the benchmarking and profiling requirements).

Finally, systems might want to consider installing enhanced coagulation, softening technology (unless hardness is a problem), or GAC technology.  This is an expensive option, however, and enhanced coagulation or lime softening would also require systems to comply with the precursor treatment technique requirement of this rule.

## Questions

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

- Q & A

## DBP Precursors

- Found naturally in water
- React with disinfectants to produce DBPs
- Reducing DBP precursors limits formation of DBPs

- DBP Precursors (DBPP)

**Notes:**
Disinfection byproduct precursors (DBP precursors) are substances like bromide and natural organic material (NOM) found in water.  DBP precursors react with disinfectants to produce harmful byproducts (DBPs), including those regulated by the Stage 1 DBPR (total trihalomethanes [TTHM], haloacetic acids [HAA5], and bromate).  Congress was prompted to create the Safe Drinking Water Act (SDWA) because of concerns with the health effects of DBPs in in drinking water.  

DBP precursors themselves do not have adverse health effects.  However, because reducing DBP precursors will reduce the formation of TTHM and HAA5, DBP precursor removal will significantly benefit public health and reduce the negative health effects associated with those byproducts and possibly others.   

Disinfection can produce hundreds of byproducts — U.S. EPA still does not know which byproducts are the most harmful.  The largest family of DBPs is trihalomethanes (THM), which is why the first DBP standard was for TTHM.  The next largest group of byproducts is haloacetic acids. U.S. EPA anticipates that by requiring systems to minimize the formation of THM and HAA5, systems would also be minimizing the formation of other byproducts.  By lowering the level of DBP precursors in water, systems will limit the formation of these byproducts. 

## DBP Precursor Treatment Technique (TT)

- Applies only to Subpart H systems using conventional filtration or enhanced softening which include these 4 filtration components:

- DBP Precursors (DBPP)

- Coagulation
- Flocculation
- Sedimentation
- Filtration

**Notes:**
This portion of the Stage 1 DBPR only applies to Subpart H conventional filtration or softening systems because these are the only plants that can achieve total organic carbon (TOC) removal in a cost-effective manner.  At the time of this rulemaking, U.S. EPA did not feel that the risks associated with DBP precursors merited the installation of new disinfection methods or expensive membranes.  However, it concluded that water treatment plants with the capability to meet a treatment technique (TT) requirement should reduce precursor levels in order to minimize the formation of byproducts.  

Ground water systems and Subpart H systems with other types of treatment trains (like direct filtration and slow sand filtration) are excluded from the TT requirement because they generally have higher quality source water and usually are not configured to remove significant levels of precursors.  For more information on the applicability of the treatment technique requirements, see 40 CFR 141.135(a).

As a reminder:
Subpart H systems are systems that use surface water or ground water under the direct influence of surface water (GWUDI).  
Conventional filtration treatment is a series of processes including coagulation, flocculation, sedimentation, and filtration resulting in substantial particulate removal.  It is also known as “complete treatment.”  Conventional treatment systems may add large quantities of coagulant (such as alum) to remove color, organics, and precursors.
Enhanced softening means the improved removal of disinfection byproduct precursors by precipitative softening.  Precipitative softening consists of adding lime or soda ash to the water to increase its pH (which is why it is commonly called lime softening).  Elevating the pH of the water precipitates calcium and magnesium out of the water.

## DBP Precursor Removal Percentages

- Removal requirements depend on source water characteristics:

**Systems practicing softening must meet TOC removal requirements in this column**

**Treatment Technique Removal Percentages:**

- DBP Precursors (DBPP)

**Notes:**
The percentage of TOC that systems will have to remove depends on the characteristics of the system’s source water.  These removal percentages were developed based on historical performance of conventional filtration and softening systems.  As source water alkalinity increases, the required removal percentage decreases because a system would have to add more and more coagulant to drive down the pH.  For more information on the required removal percentages, see 40 CFR 141.135(b)(2).

Systems using softening must meet the TOC requirements in the “greater than 120” column, regardless of their source water alkalinity.  This is due to the fact that these systems typically have very high levels of alkalinity.

## DBP Precursor Routine Monitoring Requirements

**Paired sample**

- 1 sample set per month:
- Source water alkalinity
- Source water TOC
- Treated water TOC

- DBP Precursors (DBPP)

**Notes:**
Subpart H systems using conventional filtration or softening must take one sample set (consisting of 3 samples) per month.  Systems must collect one sample of source water alkalinity, one sample of source water TOC, and one sample of treated water TOC.  The two TOC samples are called a “paired sample.”  

The source water samples (one for alkalinity and one for TOC) must be taken at the same time prior to any treatment.  The treated water sample must be taken no later than the point of combined filter effluent turbidity monitoring.  The treated water sample should be taken after the source water sample, with the time between the sampling equaling the average time it takes water to get through the treatment train.  For more information on DBP precursor monitoring requirements, see 40 CFR 141.132(d).

## DBP Precursor Monitoring Results

**30.0%**

**40%**

**50.0%**

**> 8.0**

**25.0%**

**35.0%**

**45.0%**

**> 4.0 – 8.0**

**15.0%**

**25.0%**

**35.0%**

**> 2.0 – 4.0**

**>120**

**>60-120**

**0-60**

**Source water Alkalinity (mg/L as CaCO****3**

**Source Water TOC (mg/L)**

**Treated water sample determines what percentage of TOC was removed**

- Source water samples determine TOC removal target
- Example:
- Alkalinity 65 mg/L
- Source Water TOC 9.0 mg/L

- DBP Precursors (DBPP)

## DBP Precursor Monitoring Results

**30.0%**

**40%**

**50.0%**

**> 8.0**

**25.0%**

**35.0%**

**45.0%**

**> 4.0 – 8.0**

**15.0%**

**25.0%**

**35.0%**

**> 2.0 – 4.0**

**>120**

**>60-120**

**0-60**

**Source water Alkalinity (mg/L as CaCO****3**

**Source Water TOC (mg/L)**

**Treated water sample determines what percentage of TOC was removed**

- Source water samples determine TOC removal target
- Example:
- Alkalinity 65 mg/L
- Source Water TOC 9.0 mg/L
- Required Removal Percentage = 40%

- DBP Precursors (DBPP)

**>60-120**

**> 8.0**

**40.0%**

## DBP Precursor Reduced Monitoring

- Qualify if average treated water TOC level is:
- Less than 2.0 mg/L for 2 years
- 	OR
- Less than 1.0 mg/L for 1 year
- Reduced Schedule: 1 sample set per quarter
- Return to routine if RAA of treated water TOC > 2.0 mg/L

- DBP Precursors (DBPP)

**Notes:**
Systems may be eligible for reduced monitoring if their treated water TOC 
level is either:

 Less than 2.0 mg/L for two years; or,
 Less than 1.0 mg/L for one year. 

The reduced monitoring schedule is one sample set (consisting of 3 samples—a paired TOC set and a source water alkalinity sample) per quarter.  A system on reduced monitoring must revert to routine in the month following the quarter when the annual average of treated water TOC exceeded 2.0 mg/L.

There are no increased monitoring requirements for TOC removal.

## DBP Precursor Compliance Overview

**Most systems will be able to comply through alternative compliance criteria or Step 1 TOC removal**

- DBP Precursors (DBPP)

| 1. | Step 1 TOC Removal | Covered in Today’s Presentation |
| --- | --- | --- |

**Notes:**
All systems can comply with the DBP precursor TT requirements in four different ways: 

Through one of 8 alternative compliance criteria (ACC);
Through Step 1 TOC removal (as shown in the 3 by 3 matrix);
Through Step 2 TOC removal; or,
Through a state waiver.

Two of the alternative compliance criteria are available for softening systems only.  For more information on compliance requirements for DBP precursors, see 40 CFR 141.135(a)(2), (b)(1), and (b)(2).

Systems can also mix and match compliance using options either #1, #2, or #3 from month to month.  Note that not all ACCs can be used on a monthly basis.

If a system cannot comply with Step 1, to comply through Step 2, it must apply to the state and use pilot testing results to determine an amount of TOC it can reasonably remove.  

U.S. EPA believes that most systems will be able to comply with the TT requirements through an alternative compliance criterion, Step 1 TOC removal, or a combination of alternative compliance criteria and Step 1 TOC removal.  

## DBP Precursor Compliance Overview

**Most systems will be able to comply through alternative compliance criteria or Step 1 TOC removal**

- DBP Precursors (DBPP)

| 1. | Step 1 TOC Removal | Covered in Today’s Presentation |
| --- | --- | --- |
| 2. | Alternative Compliance Criteria | Briefly Covered in Today’s Presentation  |
| 3. | Step 2 TOC Removal |  |

**Notes:**
All systems can comply with the DBP precursor TT requirements in four different ways: 

Through one of 8 alternative compliance criteria (ACC);
Through Step 1 TOC removal (as shown in the 3 by 3 matrix);
Through Step 2 TOC removal; or,
Through a state waiver.

Two of the alternative compliance criteria are available for softening systems only.  For more information on compliance requirements for DBP precursors, see 40 CFR 141.135(a)(2), (b)(1), and (b)(2).

Systems can also mix and match compliance using options either #1, #2, or #3 from month to month.  Note that not all ACCs can be used on a monthly basis.

If a system cannot comply with Step 1, to comply through Step 2, it must apply to the state and use pilot testing results to determine an amount of TOC it can reasonably remove.  

U.S. EPA believes that most systems will be able to comply with the TT requirements through an alternative compliance criterion, Step 1 TOC removal, or a combination of alternative compliance criteria and Step 1 TOC removal.  

## DBP Precursor Compliance Overview

**Most systems will be able to comply through alternative compliance criteria or Step 1 TOC removal**

- DBP Precursors (DBPP)

| 1. | Step 1 TOC Removal | Covered in Today’s Presentation |
| --- | --- | --- |
| 2. | Alternative Compliance Criteria | Briefly Covered in Today’s Presentation  |
| 3. | Step 2 TOC Removal |  |
| 4. | State Waiver | Not Covered in Today’s Presentation |

**Notes:**
All systems can comply with the DBP precursor TT requirements in four different ways: 

Through one of 8 alternative compliance criteria (ACC);
Through Step 1 TOC removal (as shown in the 3 by 3 matrix);
Through Step 2 TOC removal; or,
Through a state waiver.

Two of the alternative compliance criteria are available for softening systems only.  For more information on compliance requirements for DBP precursors, see 40 CFR 141.135(a)(2), (b)(1), and (b)(2).

Systems can also mix and match compliance using options either #1, #2, or #3 from month to month.  Note that not all ACCs can be used on a monthly basis.

If a system cannot comply with Step 1, to comply through Step 2, it must apply to the state and use pilot testing results to determine an amount of TOC it can reasonably remove.  

U.S. EPA believes that most systems will be able to comply with the TT requirements through an alternative compliance criterion, Step 1 TOC removal, or a combination of alternative compliance criteria and Step 1 TOC removal.  

## Step 1 TOC Removal

- Systems remove a percentage of TOC based on source water characteristics
- Percentage may change on a month-to-month basis
- Compliance is based on a ratio of the percentage of TOC actually removed to percentage of TOC that system should have removed
- Ratio _>_ 1.00 required to remain in compliance
- Compliance based on RAA calculated quarterly

- DBP Precursors (DBPP)

**Notes:**
To comply with the Step 1 TOC removal requirements, systems must remove a percentage of TOC through either enhanced coagulation or enhanced softening.  The percentage that systems will have to remove is based on source water alkalinity and source water TOC.   

Changes in source water characteristics may affect the TOC removal requirements from month to month – for example, a change in the TOC levels in source water from 3.0 mg/L to 4.5 mg/L from one month to the next (with alkalinity holding steady at 40 mg/L) would require the removal 35.0% of TOC the first month and 45.0% the following month.  Therefore, since systems cannot directly determine annual compliance from the percentages of TOC removed (as this will change from month to month), they will need to perform additional calculations.  

EPA requires systems to use a ratio – the percent actually removed relative to the percent removal required – to calculate compliance.  A RAA of ratios greater than or equal to 1.00 is required to remain in compliance.

## Step 1 Calculations

- Calculation 1: Determine removal ratio
- Calculation 2: Identify removal ratios for last 12 months
- Calculation 3: Calculate the RAA

- DBP Precursors (DBPP)

**Notes:**
To determine compliance with the Step 1 removal requirements, systems first determine their removal ratio on a month-by-month basis.  Next, they identify the removal ratios they must use to calculate compliance (removal ratios for the last 12 months).  Then, they calculate an RAA of removal ratios.

## Quiz#5: DBP Precursor Calculating Compliance for Step 1	

- This example is for a system meeting TOC removal requirements using the Step 1 Criteria
- What results does the system need in order to calculate compliance?

- DBP Precursors (DBPP)

## Quiz#5: DBP Precursor Calculating Compliance for Step 1

- This example is for a system meeting TOC removal requirements using the Step 1 Criteria
- What results does the system need in order to calculate compliance?

**Source Water TOC**

**Source Water Alkalinity**

**Treated Water TOC**

- DBP Precursors (DBPP)

## Quiz#5: DBP Precursor Calculating Compliance for Step 1 

- This example is for a system meeting TOC removal requirements using the Step 1 Criteria
- When should the system calculate compliance?

- DBP Precursors (DBPP)

- This example is for a system meeting TOC removal requirements using the Step 1 Criteria
- When should the system calculate compliance?

**Quarterly to Determine the RAA**

- DBP Precursors (DBPP)

- Quiz#5: DBP Precursor Calculating Compliance for Step 1

## Step 1 Example

- _A_
- Source TOC
- (mg/L)
**8.2**
**6.1**
**6.2**

- _B_
- Source
- Alk. (mg/L)
**70**
**75**
**80**

- _C_
- Required TOC
- Removal (%)
**40.0**
**35.0**
**35.0**

- _D_
- Treated TOC
- (mg/L)
**4.6**
**4.0**
**4.4**

- _E_
- % Removed
- (A-D)/A
**43.9**
**34.4**
**29.0**

**Month**
**Oct.**
**Nov.**
**Dec.**
**Jan.**
**Feb.**
**Mar.**
**Apr.**
**May**
**Jun.**
**Jul.**
**Aug.**
**Sep.**

- _F_
- E/C
**1.15**
**0.96**
**1.31**
**1.12**
**0.99**
**1.23**
**1.45**
**1.18**
**1.00**
**1.10**
**0.98**
**0.83**

**Since average is ******** 1.00, **
**the system is in compliance**

**       ****sum column (F) = 13.30**
**    ****13.33/12= 1.11**

- DBP Precursors (DBPP)

**Notes:**
This example shows how all the calculations can be performed in a one-page table, which is similar to the monitoring tracking worksheets that are provided as part of your materials.  For simplification, only the monitoring results for the most recent quarter are shown (though the removal ratios for the previous 9 months are also shown).

When completing this table, you would enter your appropriate monitoring data in columns A, B, and D.  Using the data in columns A and B, you would determine the required TOC removal percentage from the 3-by-3 matrix, which you would enter into column C.  Then you would calculate the percentage of TOC you had removed and enter that in column E.  To determine your removal ratio for each month, you would divide the percentage you actually removed (column E) by the percentage you were supposed to remove (column C).  

Once you had removal ratios for the last 12 months, you would add the removal ratios and divide by the number of months you have a ratio for (which in this case is 12).  The result, 1.11, is the RAA of your removal ratios.  In this case, you would be in compliance since the RAA is greater than 1.00.

## Alternative Compliance Criteria

- RAA of monthly source water TOC samples < 2.0 mg/L
- RAA of monthly treated water TOC samples < 2.0 mg/L
- RAA of source water TOC < 4.0 mg/L, RAA of source water alkalinity > 60 mg/L, and either:
- TTHM RAA _<_ 0.040 mg/L and HAA5 RAA _<_ 0.030 mg/L
- OR System has made a “clear and irrevocable commitment” to installing technology to limit TTHM & HAA5 to those levels
- TTHM RAA _<_ 0.040 mg/L and  HAA5 RAA _<_ 0.030 mg/L, and system uses only chlorine for primary disinfection and maintenance of a residual

- DBP Precursors (DBPP)

**Notes:**
If a system’s RAA of source water TOC is less than 2.0 mg/L, it is in compliance with alternative criterion #1 and does not have to remove TOC. 

If a system’s RAA of treated water TOC is less than 2.0 mg/L, it is in compliance with alternative criterion #2 and does not have to comply with the specified TOC removal percentages, regardless of its source water characteristics. 

If the RAA of a system’s source water TOC is less than 4.0 mg/L, the RAA of its source water alkalinity is greater than 60 mg/L, and either: 

The TTHM RAA is less than or equal to 0.040 mg/L and the HAA5 RAA is less than or equal to 0.030 mg/L (note that these levels are half the respective MCLs); or, 
The state has determined that the system have made a clear and irrevocable commitment to installing technology to limit TTHM and HAA5 to those levels

The system is in compliance with alternative criterion #3 and do not have to remove TOC.  Evidence of a clear and irrevocable commitment must have been submitted to the state before January 1, 2004 and the technology must be installed and operating by June 30, 2005.

## Alternative Compliance Criteria

- 5.	RAA of SUVA prior to any treatment < 2.0 L/mg-m
- 6.	RAA of treated water SUVA < 2.0 L/mg-m
- 7.	Softening that results in a RAA of treated water alkalinity < 60 mg/L (as calcium carbonate)
- 8.	Softening that results in a RAA for the removal of magnesium hardness (as calcium carbonate) of at least 10 mg/L

- DBP Precursors (DBPP)

**Apply only to softening systems:**

**Notes:**
If a system’s RAA of Specific Ultraviolet Absorption (SUVA—calculated using UV254 and DOC), a measure of the humic content of water, prior to any treatment (including chlorine addition), is less than or equal to 2.0 L/mg-m (liters per milligram/meter; measured monthly), it is in compliance with alternative criterion #5 and does not have to remove TOC.  

If a system’s RAA of SUVA for treated water is less than or equal to 2.0 L/mg-m (measured monthly), it is in compliance with alternative criterion #6 and does not have to remove TOC.  A more detailed discussion of SUVA is presented on the next slide.

Two additional alternative criteria are available to systems using softening:

If softening results in a RAA of treated water alkalinity of less than 60 mg/L (as calcium carbonate and measured monthly), the system is in compliance with alternative criterion #7 and does not have to remove TOC. 

If softening results in the removal of at least 10 mg/L of magnesium hardness (as calcium carbonate and measured monthly), the system is in compliance with alternative criterion #8 and does not have to remove TOC. 

Systems complying with the TT requirements through Step 1 TOC removal percentages may use most alternative compliance criteria to comply with the TOC removal requirements on a month-by-month basis.  For example, if a system’s source water TOC is less than 2.0 mg/L for one month, it may comply through alternative criterion #1 for that month.  When calculating the RAA of removal ratios to determine compliance with the Step 1 removal requirements, it would use 1.00 as a removal ratio for the months when it complied through an alternative criterion.  It would calculate the Step 1 RAA as it normally would, substituting 1.00 for an actual removal ratio for months when it complied through an alternative criterion.

Note that if a system meets an alternative compliance criterion for a month, it do not have to use a ratio of 1.00 for the TOC removal compliance calculations.  In some instances, it may be more advantageous to use the actual TOC removal ratio to calculate compliance. For more information on mixing and matching compliance criteria, see 40 CFR 141.135(c)(2)(i) through 141.135(d).

Note that alternative criteria #3 and #4 (those that rely on DBP levels) are not available for use on a month-to-month basis.

Systems complying with the TT requirements through Step 1 TOC removal percentages may use most alternative compliance criteria to comply with the TOC removal requirements on a month-by-month basis.  For example, if a system’s source water TOC is less than 2.0 mg/L for one month, it may comply through alternative criterion #1 for that month.  When calculating the RAA of removal ratios to determine compliance with the Step 1 removal requirements, it would use 1.00 as a removal ratio for the months when it complied through an alternative criterion.  It would calculate the Step 1 RAA as it normally would, substituting 1.00 for an actual removal ratio for months when it complied through an alternative criterion.

Note that if a system meets an alternative compliance criterion for a month, it do not have to use a ratio of 1.00 for the TOC removal compliance calculations.  In some instances, it may be more advantageous to use the actual TOC removal ratio to calculate compliance. For more information on mixing and matching compliance criteria, see 40 CFR 141.135(c)(2)(i) through 141.135(d).

## Step 2 TOC Removal

- If a system cannot meet Step 1 removal levels or an alternative compliance criteria, the state can set an alternate minimum TOC removal level (Step 2 removal level)
- Compliance calculations are the same, except that systems would use the alternate minimum required removal percentage to calculate their removal ratio

- DBP Precursors (DBPP)

**Notes:**
Systems that cannot meet Step 1 removal levels or an alternative compliance criteria may be able to obtain alternate minimum TOC removal levels (Step 2) from their state.  The compliance calculations are the same, except that systems would use the alternate required removal percentage to calculate the ratio.

## Step 2 TOC Removal:                            Determining alternate minimum TOC removal 

- Provide data to the state as evidence that the system cannot meet the requirements of Step 1 TOC removal
- Include the results of bench or pilot testing
- Perform Jar Testing: add 10 mg/L increments of alum
- Continue adding alum until pH  Step 2 target pH
- Add coagulant until TOC removal  0.3 mg/L for an incremental addition of 10 mg/L of alum or ferric salt at the target pH level
- The percentage of TOC removed at this level will become your “TOC removal vs. coagulant dose” and the system’s minimum TOC removal requirement.
- The state will determine an alternate removal level

- DBP Precursors (DBPP)

**Notes:**
Systems that cannot meet Step 1 removal levels or an alternative compliance criteria may be able to obtain alternate minimum TOC removal levels (Step 2) from their state.  The compliance calculations are the same, except that systems would use the alternate required removal percentage to calculate the ratio.

## Step 1 & 2: Compliance Reporting

- Reports must be submitted quarterly:
- The number of paired (source water and treated water) samples collected during the last quarter
- The location, date, and results of each paired sample and associated alkalinity taken during the last quarter
- For each month in the reporting period, the arithmetic average of the percent reduction of TOC for each paired sample and the required TOC percent removal
- Calculations for determining compliance with the TOC percent removal requirements
- Whether the system is in compliance with the enhanced coagulation or enhanced softening percent removal requirements for the last four quarters

- DBP Precursors (DBPP)

**Notes:**
Systems must submit reports for Step 1 or Step 2 every quarter.  The same information should be included in the Step 1 and Step 2 reports: the number of paired samples collected during the last quarter; the location, date, and results of all samples taken during the quarter; the monthly average of percent of TOC removed for each paired sample and the TOC removal required; compliance calculations; and whether the system is in compliance for the last 4 quarters.  For more information on reporting requirements for DBP precursors, see 40 CFR 141.134(d).

## PN Rule Requirements

**A system is out of compliance if it does not comply with the Step 1 or Step 2 removal requirements and fails to meet an alternative compliance criterion**

**Notify customers within 30 days**
**Send a copy of PN to the state within 10 days of **
** ****	****notifying customers**

**If a system commits a monitoring violation, it must inform the state and its customers**

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

- DBP Precursors (DBPP)

**Notes:**
If a system violates the DBP precursor TT requirements, it must report the violation to the state within 48 hours (40 CFR 141.31(b)).  TT violations require Tier 2 public notice as soon as practical but no later than 30 days after the system learns of the violation.  Public notifications (PN) must include the specific health effects language for TOC from Appendix B of Subpart Q of 40 CFR 141:

TOC: “Total organic carbon (TOC) has no health effects.  However, total organic carbon provides a medium for the formation of disinfection byproducts.  These byproducts include trihalomethanes (THM) and haloacetic acids (HAA).  Drinking water containing these byproducts in excess of the MCL may lead to adverse health effects, liver or kidney problems, or nervous system effects, and may lead to an increased risk of getting cancer.”

Systems must provide notice to each customer receiving a bill, to other service connections to which water is delivered by the system, and to other people regularly served by the system who would not be otherwise notified (e.g., house renters, students, nursing home patients, prison inmates).  There are a variety of ways to distribute violation notices to the public: door-to-door delivery; direct mail; public postings; and newspaper or radio announcements.

Systems must confirm that all PN requirements have been met and include a copy of the PN in a letter to the state within 10 days of notifying their customers.

If a system fails to prepare and/or submit a monitoring plan or monitor according to its monitoring plan, it has committed a monitoring violation.  If its failure to monitor makes it impossible to determine compliance with the TT, it has also committed a TT violation.  For example, if the system is complying through Step 1 removal requirements and fails to take its monthly 3-sample set for one year, and is unable to comply through an alternative criterion or Step 2 removal requirements, it has committed a TT violation.

All monitoring violations must be reported to the state and to customers.  Generally, monitoring violations require Tier 3 public notice, that is, the public must be notified within 12 months of learning of the violation.  Systems may include the notification in their Consumer Confidence Report (CCR) if it is published in time to satisfy the 12-month deadline.  However, states may impose more stringent PN requirements.  

## Returning to Compliance

- Options for systems with compliance problems:
- BATs
- Source water changes
- Partnership with other system(s)
- Modify treatment

- DBP Precursors (DBPP)

**Notes:**
If a system is having difficulty complying with the MCLs, there are several options to consider to return to compliance. EPA has specified best available technologies (BATs) for the TTHM and HAA5 MCLs.  These BATs are effective in controlling chemicals in drinking water and are affordable for systems.  The EPA-specified BATs for TTHM and HAA5 are enhanced coagulation, enhanced softening, or granular activated carbon (GAC 10), with chlorine as the primary and residual disinfectant.  For more information on BATs for TTHM and HAA5, see 40 CFR 141.64(c).

Systems might also want to consider new source water options.  If raw water NOM levels are high, blending raw water with water from a source with lower NOM levels might be an option.  Abandoning an existing source is also an option, though it can be expensive and may present new problems, like compliance with other regulations.  If microbial problems stem from poor quality source water, increased source water protection efforts may resolve the issue.  Protecting source water may help reduce microbial problems and thus disinfectant levels required to inactivate microbials.

If water quality continues to be a problem, partnerships with another system might help resolve the problem.  Partnerships can take the form of joining with one or more communities to form a consolidated system or purchasing water from another established system.

Replacing disinfection or oxidation methods may also help return to compliance.  Some options include decreasing contact time and/or the concentration of the disinfectant, adjusting the pH, or changing disinfectants.  Chloramines generally produce fewer byproducts than chlorine.  Systems using chlorine may want to consider using chloramines instead (especially for secondary disinfection).  Other alternatives include combining disinfectants, potassium permanganate, peroxone, or UV radiation.  When considering a change in disinfection or oxidation methods, systems should be aware that the Surface Water Treatment Rule requires Subpart H systems to achieve at least the same level of microbial removal it is currently achieving if it changes its disinfection practices (part of the benchmarking and profiling requirements).

Finally, systems might want to consider installing enhanced coagulation, softening technology (unless hardness is a problem), or GAC technology.  This is an expensive option, however, and enhanced coagulation or lime softening would also require systems to comply with the precursor treatment technique requirement of this rule.

## Poll: How many people are attending at your location?

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**1 Person**
**2 - 4 People**
**5 - 10 People**
**10 - 20 People**
**More than 20 People**

## Questions?

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

- Q & A

## Case Studies: Great View

- Where, when, & how many chlorine samples should this system take?
- What is the system’s RAA for chlorine?
- What is the system required to report to the state within 10 days?
- Where, when, & how many TTHM & HAA5 samples should this system take?
- What is the system’s RAA for TTHMs?

- Case Studies

- GW System, serving 300, taking quarterly TCR samples

## Case Studies: Great View

- GW System, serving 300, taking quarterly TCR samples

**Notes:**
Ask them to switch their seat color when they have their answers and are ready to poll.

## Poll: Where, when, & how many chlorine samples should this s...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- One per year at MRT
- Five samples per month and taken 25% at MRT and 75% at ART
- The same number and at the same time and place as TCR

## Answer

- Where, when, & how many chlorine samples should this system take?
- The same number and at the same time and place as TCR

- GW System, serving 300, taking quarterly TCR samples

- Case Studies

## Poll: What is the system’s RAA for chlorine?

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- 1.2 mg/L
- 1.4 mg/L
- 1.6 mg/L
- None of the above

## Answer

- What is the system’s RAA for chlorine?
- 1.4 mg/L
- 1 + 1 + 1.5 + 1 + 1.5 + 2 + 1 + 3 + 1.5 + 1 + 1 + 1.5 = 17
- 17/12 = 1.4 mg/L

- GW System, serving 300, taking quarterly TCR samples

- Case Studies

## Poll: What is the system required to report to the state wit...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- Number of samples taken during each month of the last quarter
- The monthly arithmetic average of all samples taken in each month for the last 12 months
- The arithmetic average of the monthly averages for the last 12 months and whether the MRDL was violated
- All of the above

## Answer

- What is the system required to report to the state within 10 days?
- All of the above

- GW System, serving 300, taking quarterly TCR samples

- Case Studies

## Poll: Where, when, & how many TTHM & HAA5 samples should thi...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- 1 sample per treatment plant; in the month of warmest water temperature; at the MRT
- September at the entry point to the distribution system
- The same number and at the same time and place as TCR
- 5 samples per month; 25% at MRT and 75% at ART

## Answer

- Where, when, & how many TTHM & HAA5 samples should this system take?
- 1 sample per treatment plant; in the month of warmest water temperature; at the MRT

- GW System, serving 300, taking quarterly TCR samples

- Case Studies

## Poll: What is the system’s RAA for TTHMs?

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- 0.040 mg/L
- 0.055 mg/L
- 0.070 mg/L
- None of the above

## Answer

- What is the system’s RAA for TTHMs?
- 0.070 mg/L

- GW System, serving 300, taking quarterly TCR samples

- Case Studies

## Case Studies: Smithville

- How many chlorine samples should this system take in August 2005?
- Where and when should the system take chlorine samples?
- Where, when, & how many TTHM & HAA5 samples should the system take?
- What is the system’s RAA for TTHMs & HAA5?
- Does the system have to perform public notification?
- What does the system need to do to return to compliance?

- Case Studies

- GW System, serving 11,000, taking monthly TCR samples due to TC + in July 05

## Case Studies: Smithville

- Case Studies

**Q3 2010: 0.09 **
**Q2 2010:** **0.05 **
**Q1 2010:** **0.08**
**Q4 2009:** **0.04**

** ****Q3 2009:** **0.04**
**Q2 2009:** **0.08**
**Q1 2009:** **0.06**
**Q4 2008:** **0.07**

**TTHM Results for last 8 quarters:**

**Q3 2010:** **0.07 **
**Q2 2010:** **0.08 **
**Q1 2010:** **0.07**
**Q4 2009:** **0.09**

**Q3 2009:** **0.04**
**Q2 2009:** **0.08**
**Q1 2009:** **0.06**
**Q4 2008:** **0.07**

**HAA5 Results for last 8 quarters:**

- GW System, serving 11,000, taking monthly TCR samples due to TC + in July 05

## Poll: How many chlorine samples should this system take in A...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- 15 samples
- 10 samples
- 5 samples
- 1 sample

## Answer

- How many chlorine samples should this system take in August 2005?
- 10 samples – The same as the number of TCR samples required.

- GW System, serving 11,000, taking monthly TCR samples due to TC + in July 05

- Case Studies

## Poll: Where and when should the system take chlorine samples...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- In the month of warmest water temperature at the MRT
- 25% at MRT and 75% at ART
- Same time and place as TCR
- Quarterly at MRT

## Answer

- Where and when should the system take chlorine samples?
- Same time and place as TCR

- GW System, serving 11,000, taking monthly TCR samples due to TC + in July 05

- Case Studies

## Poll: Where, when, & how many TTHM & HAA5 samples should thi...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- 1 sample per treatment plant; in the month of warmest water temperature; at the MRT
- 1 sample per treatment plant per quarter at MRT
- The same number and at the same time and place as TCR
- 5 samples per month; 25% at MRT and 75% at ART

## Answer

- Where, when, & how many TTHM & HAA5 samples should this system take?
- 1 sample per treatment plant per quarter at MRT

- Case Studies

- GW System, serving 11,000, taking monthly TCR samples due to TC + in July 05

## Poll: What is the system’s RAA for TTHMs & HAA5?

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- TTHM = 0.085 mg/L & HAA5 = 0.046 mg/L
- TTHM = 0.013 mg/L & HAA5 = 0.02 mg/L
- TTHM = 0.065 mg/L & HAA5 = 0.078 mg/L
- None of the above

## Answer

- What is the system’s RAA for TTHMs & HAA5?
- TTHM = 0.065 mg/L & HAA5 = 0.078 mg/L
- TTHMs RAA
- 0.09 + 0.05 + 0.08 + 0.04 = 0.26
- 0.26/4 = 0.065 mg/L
- HAA5s RAA
- 0.07 + 0.08 + 0.07 + 0.09 = 0.31
- 0.31/4 = 0.078 mg/L

- GW System, serving 11,000, taking monthly TCR samples due to TC + in July 05

- Case Studies

## Poll: Does the system have to perform public notification?

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- Yes
- No

## Answer

- Does the system have to perform public notification?
- Yes
- MCL violation because the HAA5 RAA of 0.078 mg/L exceeds the MCL of 0.060 mg/L

- GW System, serving 11,000, taking monthly TCR samples due to TC + in July 05

- Case Studies

## Poll: What does the system need to do to return to complianc...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- RAA in following quarter needs to be equal to or less than 0.060 mg/L
- System needs to monitor for 1 year
- RAA in the following month needs to be equal to or  less than 0.060 mg/L

## Answer

- What does the system need to do to return to compliance?
- RAA in following quarter needs to be less than 0.060 mg/L

- GW System, serving 11,000, taking monthly TCR samples due to TC + in July 05

- Case Studies

## Case Studies: Crystal Lake

- Where, when, & how many chlorine samples should this system take?
- What is the system’s RAA for chlorine?
- Where, when, & how many TTHM & HAA5 samples should the system take?
- What is the system’s RAA for TTHMs & HAA5?
- What is the system’s required TOC removal percentage, actual TOC removal percentage, and actual TOC removal ratio?
- Does the system need to perform public notification?

- SW System, serving 550.  System has two conventional filtration plants

- Case Studies

## Case Studies: Crystal Lake

- Case Studies

- SW System, serving 550.  System has two conventional filtration plants

| Source Water Alkalinity | 65 mg/L |
| --- | --- |
| Source Water TOC | 9.0 mg/L |
| Treated Water TOC | 4.0 mg/L |

**For this example sample set results are the same for each month and are:**

## Case Studies: Crystal Lake

- Case Studies

- SW System, serving 550.  System has two conventional filtration plants

**0.09 **
**0.05 **
**0.03**
**0.02 **
**0.04 **
**0.08 **

**0.06 **
**0.07 **
**0.02**
**0.05 **
**0.03 **
**0.02**

**TTHM Results for last 6 quarters:**

**MRT Plant 1**

**MRT Plant 2**

** ****0.02 **
**0.08 **
**0.04**
**0.02 **
**0.04 **
**0.08 **

**0.04 **
**0.02 **
**0.04 **
**0.08 **
**0.06 **
**0.07**

**HAA5 Results for last 6 quarters:**

**MRT Plant 1**

**MRT Plant 2**

**Q2 2007 **
**Q1 2007**
**Q4 2006**
**Q3 2006**
**Q2 2006**
**Q1 2006**

## Poll: Where, when, & how many chlorine samples should this s...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- Four per year in month of warmest water temperature 75% at ART and 25% at MRT
- Five samples per month and taken 25% at MRT and 75% at ART
- The same number and at the same time and place as TCR
- None of the above

## Answer

- Where, when, & how many chlorine samples should this system take?
- The same number and at the same time and place as TCR

- Case Studies

- SW System, serving 550.  System has two conventional filtration plants

## Poll: What is the system’s RAA for chlorine?

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- 1.6 mg/L
- 1.8 mg/L
- 2.0 mg/L
- None of the above

## Answer

- What is the system’s RAA for chlorine?
- 1.8 mg/L
- 1 + 1.5 + 2 + 2 + 1 + 1.5 + 2 + 1 + 1 + 1.5 + 5 + 1.5 = 21
- 21/12 = 1.8 mg/L

- Case Studies

- SW System, serving 550.  System has two conventional filtration plants

## Poll: Where, when, & how many TTHM & HAA5 samples should thi...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- 1 sample per treatment plant; in the month of warmest water temperature; at the MRT
- 1 sample per treatment plant per quarter at MRT
- The same number and at the same time and place as TCR
- 5 samples per month; 25% at MRT and 75% at ART

## Answer

- Where, when, & how many TTHM & HAA5 samples should this system take?
- 1 sample per treatment plant per quarter at MRT

- Case Studies

- SW System, serving 550.  System has two conventional filtration plants

## Poll: What is the system’s RAA for TTHMs & HAA5?

- [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]
- TTHMs = 0.085 mg/L; HAA5 = 0.095 mg/L
- TTHMs = 0.049 mg/L; HAA5 = 0.043 mg/L
- TTHMs = 0.035 mg/L; HAA5 = 0.023 mg/L

## Answer

- What is the system’s RAA for TTHMs & HAA5?
- TTHM = 0.049 mg/L & HAA5 = 0.043 mg/L
- TTHMs RAA
- (0.09 + 0.06)/2 + (0.05 + 0.07)/2 + (0.03 + 0.02)/2 + (0.02 + 0.05)/2 = 0.195 mg/L
- 0.195/4 = 0.049 mg/L
- HAA5s RAA
- (0.02 + 0.04)/2 + (0.08 + 0.02)/2 + (0.04 + 0.04)/2 + (0.02 + 0.08)/2 = 0.17 mg/L
- 0.17/4 = 0.043 mg/L

- Case Studies

- SW System, serving 550.  System has two conventional filtration plants

## Poll: What is the system’s required TOC removal percentage, ...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- 40%; 55.6%; 1.39
- 45%; 22.5%; 0.5
- 15%; 50%; 3.33
- 30%; 40%; 1.33

## Answer

- What is the system’s required TOC removal percentage, actual TOC removal percentage, and actual TOC removal ratio?
- 40%; 55.6%; 1.39
- Required removal % = 40% (from 3 by 3 Matrix)
- Actual removal % = 55.6% ((9-4)/9)
- Actual removal ratio = 1.39 (55.6% / 40.0%)

- Case Studies

- SW System, serving 550.  System has two conventional filtration plants

## Poll: Does the system need to perform public notification?

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- Yes
- No

## Answer

- Does the system need to perform public notification?
- No.
- Because the example assumed that the system had the same alkalinity and TOC numbers each month
- Therefore the removal ratio would be the same for each month.
- The removal ratio is 1.39 for the year which is greater than 1.00 so the system is in compliance.

- Case Studies

- SW System, serving 550.  System has two conventional filtration plants

## Upcoming Regulations

- Expected final in December 2005
- Stage 2 DBPR
- LT2ESWTR
- Ground Water Rule

- Stage 2

**Notes:**
In addition to the rules already mentioned, three upcoming regulations may present simultaneous compliance issues for systems.  These rules have not yet been promulgated, but are in the draft/proposal stage and may be finalized soon. 

The Stage 2 DBPR, along with the LT2ESWTR, is intended to expand existing public health protections and address concerns about risk trade-offs between pathogens and DBPs.  Promulgating the LT2ESWTR and the Stage 2 DBPR together is necessary to ensure that adequate protection from microbial risk is maintained while systems reduce the risk from DBPs.  

In developing the Stage 2 DBPR, EPA analyzed new survey data on source water quality parameters, treatment data, and DBP occurrence.  This data, which was collected under the Information Collection Rule (ICR), Supplemental Surveys to the ICR, and additional research projects, will provide a more comprehensive and complete picture of the occurrence of DBPs and microbiological pathogens. EPA is also using new information on the health effects of exposure to DBPs to determine effective regulatory requirements for controlling risk.

EPA has designed the LT2ESWTR to expand on the LT1ESWTR by incorporating new survey data on microbial pathogens in source and finished waters, as well as data on parameters which could serve as indicators of microbial risk.  This data will provide a substantially more comprehensive and complete picture of the occurrence of waterborne pathogens. EPA is also using new data on both the efficiency of treatment processes in removing and inactivating microorganisms and the pathogenicity of certain pathogens to determine effective regulatory requirements for controlling microbial risk.

The Ground Water Rule (GWR) was proposed in August 2000.  It is intended to extend requirements similar to the LT1ESWTR and the IESWTR to ground water systems in order to protect public health. The proposed rule calls for periodic sanitary surveys of ground water systems; hydrogeologic assessments to identify wells sensitive to fecal contamination; source water monitoring; and correction of significant deficiencies and fecal contamination.

## Stage 2 DBPR Preview

- Applies to CWSs and NTNCWSs
- Consecutive Systems
- Designed to reduce peak DBP concentrations
- Proposed changes to TTHM and HAA5 requirements:
- Monitoring locations
- Method of calculating RAA
- Importance of data and knowledge from Stage 1 DBPR!

- Stage 2

**Notes:**
The Stage 2 DBPR will apply to the same systems as the Stage 1 DBPR (though it will clarify the requirements for consecutive systems and systems purchasing water).  Its requirements will be designed to reduce DBP occurrence peaks in distribution systems.  These changes will further reduce negative reproductive and developmental health effects, as well as reduce cancer rates. 

EPA hopes to reduce peak DBP concentrations in part by changing the monitoring locations set by the Stage 1 DBPR.  To determine new monitoring locations, most systems will be required to perform an Initial Distribution System Evaluation (IDSE), or a study to select new compliance monitoring locations that better represent high TTHM and HAA5 concentrations in distribution systems. This is especially true for HAA5, which generally decomposes in the distribution system before it reaches the end of the system.  The Stage 2 DBPR will ensure that customers located throughout the entire distribution system will receive water with low levels of DBPs.

EPA will coordinate the implementation of the LT2ESWTR and the Stage 2 DBPR because coordination ensures that protection against microbial pathogens is not compromised by efforts to reduce DBP formation.  The LT2ESWTR will apply to all Subpart H systems.  This rule will provide further protection of public health by requiring systems that are highly vulnerable to Cryptosporidium to provide additional treatment for this pathogen.

## Poll: Does your state require consecutive systems to comply ...

*[PlaceWare Multiple Choice Poll. Use ****PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- No requirements
- Monitor and comply independently
- Monitor as part of a combined distribution system independently or as part of the combined system

## Evaluation Form

- Available in the Handouts Sent to Your Site Coordinator
- Please Complete and Then...
-  Fax Directly (fax number on the form) or email to webcastinfo@cadmusgroup.com

**Join us for Consumer Confidence Report Web cast Training **
**Wednesday, May 25, 2005, 2 – 4 PM**

- Additional Resources

## Questions?

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

- Q & A

## Additional Stage 1 DBPR Resources

**for Further Study of the Federal Rule**

## Stage 1 DBPR Webcast Materials

- Drinking Water Academy Web site: _[www.epa.gov/safewater/dwa.html](http://www.epa.gov/safewater/dwa.html)__ _
- Available – May 16, 2005
- Web cast Presentation Slides
- Written Q&A from Web cast

- Additional Resources

**Notes:**
Under DWA Calendar for future Web cast Trainings

## Additional Stage 1 DBPR Resources

- Quick Reference Guides:
- Stage 1 DBPR Rule (EPA 816-F-01-010)
- State 1 DBPR Laboratory Quick Reference Guide (EPA 816-F-02-021)
- 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

## EPA Resources Available

- Implementation guidance documents:
- Stage 1 DBPR Final Implementation Guidance
- 	(EPA 816-R-01-012)
- Stage 1 DBPR Plain English Guidance
- 	(EPA 816-R-01-014)
- General M-DBP Fact Sheet
- 	(EPA 816-F-01-012)
- Profiling and Benchmarking Fact Sheet
- 	(EPA 816-F-98-0176)
- Stage 1 DBPR Fact Sheet
- 	(EPA 816-F-01-014)
- A Small System Guide to the Stage 1 DBPR (in development)

- Additional Resources

## EPA Resources Available

- All documents available through EPA’s M-DBP Web site or by calling the Safe Drinking Water Hotline:
- _[http://www.epa.gov/safewater/mdbp/implement.html](http://www.epa.gov/safewater/mdbp/implement.html)_
- 1-800-426-4791

- Additional Resources

## For More Questions

- Send Your State’s Stage 1 Questions or Situations to:
- _[MDBP_OGWDW@epa.gov](mailto:MDBP_OGWDW@epa.gov)__ _
- Stage 1 DBPR Questions:  Call your EPA Regional Office or Ed Moriarty, US EPA HQ 202-564-3864

- Additional Resources

## Next Webcast: Consumer Confidence Report

- Wednesday, May 25, 2005, 2 – 4 PM (EST)
- Topics to be covered:
- Report Content Overview
- Interpreting and Reporting Data
- Reviewing CCR for Compliance
- Risk Communication Overview
- CCR*i*Writer Demonstration

- Additional Resources

## Webcast Series

- See Handout or DWA Calendar for Upcoming 2005 Web casts
- _[http://www.epa.gov/safewater/dwa/calendar.html](http://www.epa.gov/safewater/dwa/calendar.html)__ _
- Future Web casts 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 Stage 1 DBPR
- Will Open for Registration Six Weeks Prior to Each Webcast

- Additional Resources