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State of Alaska Implementation of MBDP Rules

State of Alaska Implementation of MBDP Rules. Carrie Bohan Environmental Program Specialist ADEC DW Program. Basic Requirements. Stage 1 D/DBR. Rule promulgated by US EPA December 16, 1998 Adopted by the State of Alaska on September 28, 2001

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State of Alaska Implementation of MBDP Rules

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  1. State of AlaskaImplementation of MBDP Rules Carrie Bohan Environmental Program Specialist ADEC DW Program

  2. Basic Requirements Stage 1 D/DBR • Rule promulgated by US EPA December 16, 1998 • Adopted by the State of Alaska on September 28, 2001 • Effective for surface water systems or GWUDISW systems (Subpart H) serving 10,000+ on January 1, 2002 • Effective for surface water or GWUDISW systems serving <10,000, and all ground water systems on January 1, 2004 • CWS, NTNCWS and TNCWS using chlorine dioxide

  3. Basic Requirements Stage 1 D/DBR • Basic Requirements • MCLs and monitoring requirements for TTHMs, HAA5s, Bromate, and Chlorite • MRDL for Chlorine, Chloramines and Chlorine Dioxide • Treatment technique for enhanced coagulation/softening to improve precursor removal for conventional filtration plants

  4. Basic Requirements Stage 1 D/DBR • Monitoring Requirements

  5. Compliance Determination Stage 1 D/DBR • Compliance Determination • If monitoring annually, results of one annual sample • If exceed the MCL, must go to quarterly sampling • If monitoring quarterly, average of past four quarters (running annual average) • Monthly samples are averaged quarterly, compliance is based on running annual average of quarterly averages

  6. Compliance Determination Stage 1 D/DBR • Violation Types • MCL Violations • TTHMs, HAA5s, Bromate, Chlorite • MRDL Violations • Chlorine, Chloramines • Treatment Technique Violations • Not meeting Precursor Removal • Monitoring and Reporting Violations • Not collecting any individual sample • Most commonly distribution system chlorine residual • Not submitting reporting forms in a timely fashion • Public Notification Violations • Failure to conduct PN as required for violations • Acute – 24 hours, MCL/TT – 30 days, M/R – 1 year

  7. Compliance Determination Stage 1 D/DBR • Reporting Forms • www.dec.state.ak.us/eh/dw/publications/forms.html • Quarterly TTHM/HAA5 RAA reports • Quarterly Bromate/Bromide Reports • Quarterly MRDL reports • Quarterly Enhanced Coagulation Reports

  8. Compliance Determination Stage 1 D/DBR • Significant Non-Complier List (SNC) • Monthly Monitoring (Chlorine residual, MRDL) • A combination of 4 or more MCL or MRDL violations in any 12 consecutive months • A combination of 6 or more MCL, MRDL and Major Monitoring/Reporting violations in any 12 consecutive months • A combination of 10 or more MCL, MRDL, Major and Minor M/R violations in any 12 consecutive months

  9. Compliance Determination Stage 1 D/DBR • Significant Non-Complier List (SNC) • Quarterly Monitoring (TTHM/HAA5s, Bromate) • A combination of 2 or more MCL, MRDL, Treatment Technique, and Major M/R violations in any 12 consecutive months • A combination of 3 or more MCL, MRDL, Treatment Technique, and Major or Minor M/R violations in any 12 consecutive months • Annual or Less Frequent Monitoring • Failing to collect or report all required samples • If exceed the MCL, go to quarterly monitoring, no violation • Also…. • Failure to obtain State approval before making significant changes to existing treatment process

  10. Compliance Determination Stage 1 D/DBR • Significant Non-Complier List (SNC) • All SNC violations for Stage 1 take 12 months to Return to Compliance, or until the end of the quarterly violation • Example...

  11. Compliance Determination Stage 1 D/DBR • Example System A Surface water system serving 425 August 2007 Annual samples TTHM 82 ug/L HAA5 90 ug/L No Violation Must begin quarterly samples TTHM HAA5 Q4 2007 78 ug/L 93 ug/L Q1 2008 83 ug/L 101 ug/L Q2 2008 67 ug/L 69 ug/L Q3 2008 88 ug/L 78 ug/L RAA 79 ug/L 85.3 ug/L

  12. Compliance Determination TTHM HAA5 Q4 2007 78 ug/L 93 ug/L Q1 2008 83 ug/L 101 ug/L Q2 2008 67 ug/L 69 ug/L Q3 2008 88 ug/L 78 ug/L RAA 79 ug/L 85.3 ug/L Stage 1 D/DBR • Example System A Q3 2008 System receives an MCL violation for Q3 2008 Must continue quarterly sampling

  13. Compliance Determination TTHM HAA5 Q1 2008 83 ug/L 101 ug/L Q2 2008 67 ug/L 69 ug/L Q3 2008 88 ug/L 78 ug/L Q4 2008 72 ug/L 86 ug/L RAA 77.5 ug/L 83.5 ug/L Stage 1 D/DBR • Example System A Q4 2008 Second consecutive quarterly MCL violation for HAA5s Qualifies for SNC status

  14. Compliance Determination TTHM TTHM HAA5 HAA5 Q4 2008 Q1 2008 72 ug/L 83 ug/L 101 ug/L 86 ug/L Q1 2009 Q2 2008 67 ug/L 64 ug/L 57 ug/L 69 ug/L Q3 2008 Q2 2009 88 ug/L 68 ug/L 51 ug/L 78 ug/L Q4 2008 Q3 2009 62 ug/L 72 ug/L 43 ug/L 86 ug/L RAA RAA 66.5 ug/L 77.5 ug/L 83.5 ug/L 59.3 ug/L Stage 1 D/DBR • Example System A Q4 2008 Can take up to 1 year of lower results to bring the RAA below the MCL. Receives quarterly MCL violations until RAA is below the MCL.

  15. Compliance Determination TTHM TTHM HAA5 HAA5 Q4 2008 Q3 2009 72 ug/L 62 ug/L 86 ug/L 43 ug/L Q4 2009 Q1 2009 64 ug/L 59 ug/L 57 ug/L 46 ug/L Q2 2009 Q1 2010 68 ug/L 61 ug/L 51 ug/L 51 ug/L Q3 2009 Q2 2010 62 ug/L 66 ug/L 47 ug/L 43 ug/L RAA RAA 66.5 ug/L 62 ug/L 46.8 ug/L 59.3 ug/L Stage 1 D/DBR • Example System A Q2 2010 Q3 2009 Once RAA is below the MCL, will take one year to come off the SNC List.

  16. Compliance Determination TTHM TTHM HAA5 HAA5 Q3 2009 Q4 2007 62 ug/L 78 ug/L 43 ug/L 93 ug/L Q1 2008 Q4 2009 59 ug/L 83 ug/L 46 ug/L 101 ug/L Q1 2010 Q2 2008 67 ug/L 61 ug/L 69 ug/L 51 ug/L Q2 2010 Q3 2008 66 ug/L 88 ug/L 47 ug/L 78 ug/L RAA RAA 79 ug/L 62 ug/L 85.3 ug/L 46.8 ug/L Stage 1 D/DBR • Example System A In this example, it took 2 years from the initial violation to come off the SNC List.

  17. Compliance Determination Stage 2 D/DBR • Rule promulgated January 4, 2006 • State has 2 years to adopt • January 4, 2008 • Have applied for a 2 year extension • January 4, 2010 • No early implementation by the State • Until Alaska adopts the rule, systems will work directly with EPA

  18. Compliance Determination Stage 2 D/DBR • Assuming the State adopts in early 2010 • All systems will submit 40/30 certifications, VSS waiver requests, Standard Monitoring or System Specific Study plans to EPA • Schedule 1 and 2 systems will conduct Standard Monitoring or System Specific Study sampling and submit the IDSE report to EPA • Schedule 3 and 4 systems will submit IDSE report to ADEC

  19. Compliance Determination Stage 2 D/DBR • Violations Types • Monitoring/Reporting Violations • Failure to submit Monitoring Plan on time • Failure to monitor • MCL violation • LRAA exceeds the MCL • SNC Lists • EPA has not yet determined SNC definitions

  20. Basic Requirements IESWTR/LT1 • Promulgated December 16, 1998 and January 14, 2005, respectively • Lowered turbidity treatment technique standards • Requires individual filter effluent turbidity monitoring • Follow up activities for exceeding certain triggers • Filter Profile, Filter Self Assessment, Comprehensive Performance Evaluation • Filtered systems must meet 2-log Crypto removal • Increased sanitary survey frequency, no new uncovered finished water storage tanks

  21. Basic Requirements IESWTR/LT1 • Promulgated December 16, 1998 and January 14, 2002, respectively • Lowered turbidity treatment technique standards • Requires continuous individual filter effluent turbidity monitoring • Follow up activities for exceeding certain triggers • Filter Profile, Filter Self Assessment, Comprehensive Performance Evaluation • Filtered systems must meet 2-log Crypto removal • Increased sanitary survey frequency, no new uncovered finished water storage tanks

  22. Compliance Determination IESWTR/LT1 ** SWTR violations • Types of Violations • Monitoring/Reporting • Failure to conduct daily entry point chlorine residual monitoring** • Failure to conduct distribution system chlorine residual monitoring at the same time and location as monthly bacti** • Failure to conduct daily treated water turbidity monitoring** • Failure to conduct continuous individual filter effluent monitoring • Failure to conduct triggered activity from IFE readings • Failure to submit monthly reports on time • Failure to conduct Disinfection Profile & Benchmark if required • Failure to report turbidity MCL violation within 24 hours

  23. Compliance Determination IESWTR/LT1 • Types of Violations • Treatment Technique Violations • Failure to meet 2-log removal of Cryptosporidium • Failure to meet turbidity standards • Alternative filtration – 1.49 NTUs 95% of samples • Direct/Conventional filtration – 0.3 NTUs in 95% of samples • MCL Violations • Exceeding the turbidity MCL • Alternate filtration – 5 NTUs • Direct/Conventional filtration – 1.49 NTUs • Public Notification Violations • Failure to conduct PN as required for violations

  24. Compliance Determination IESWTR/LT1 • Reporting forms • http://www.dec.state.ak.us/eh/dw/publications/forms.html • 4 Versions • Direct/Conventional systems with 3 or more filters • Continuous IFE turbidity monitoring • Direct/Conventional systems with 1 or 2 filters • Continuous CFE turbidity monitoring in lieu of continuous IFE monitoring • Alternative/slow sand systems • Alternative/slow sand systems with reduced monitoring • Serve less than 500, reduced to one chlorine residual reading per day

  25. Compliance Determination IESWTR/LT1 • Significant Non-Complier List (SNC) • Unfiltered Systems • Systems that fail avoidance criteria and do not install filtration within 18 months • 3 or more Major M/R violations in any 12 consecutive months • 5 or more Major and/or Minor M/R violations in any 12 consecutive months • Filtered Systems • 4 or more TT violations in any 12 consecutive months • 6 or more TT and/or Major M/R violations in any in 12 consecutive months • 10 or more TT, Major and/or Minor M/R violations in any 12 consecutive months • All SNC violations for SWTRs take 6 months to Return to Compliance

  26. Basic Information LT2 • Promulgated January 5, 2006 • State has 2 years to adopt • January 5, 2008 • Have applied for a 2 year extension • January 5, 2010 • No early implementation by the State • All plan reviews for new systems or system improvements are held to LT2 standards • Until Alaska adopts the rule, systems will work directly with EPA

  27. Rule Adoption LT2 • Assuming the State adopts in early 2010 • All systems will submit to EPA • Samples schedules for initial source water monitoring • Results of initial source water monitoring • Notification of uncovered finished water storage tanks • Schedule 1 and 2 systems will submit Bin Classification or mean Crypto sample results to EPA • Schedule 3 system will submit Bin Classification or mean Crypto sample results to ADEC • Schedule 4 systems required to conduct Crypto monitoring will submit sample schedules to ADEC

  28. Compliance Determination LT2 • Violations • Monitoring/Reporting Violations • Failure to submit monitoring plan • Failure to conduct e.coli monitoring • Failure to collect a sample within the 5-day period around a scheduled date (unless extenuating)

  29. Compliance Determination LT2 • Violations • Treatment Technique Violations • Failure to collect Crypto samples to determine bin classification • Failure to provide required treatment by the established compliance date • Failure to meet monthly Crypto inactivation requirements • Ozone or Chlorine dioxide – more than 1 day per month • UV – more than 5% of water delivered • Failure to meet IFE performance criteria for tool box credit • SNC List • EPA has not yet determined SNC definitions

  30. Compliance Determination LT2 • Reporting Forms • New reporting forms are in the works for LT2 • Membrane filtration • Direct and indirect integrity testing requirements • UV • Calculated dose, set point approach • Ozone

  31. More Information • EPA’s MDBP Website • http://www.epa.gov/safewater/mdbp/mdbp.html • Quick Reference Guides and Fact Sheets broken down by schedule number • Source Water Monitoring Guide for LT2 • UV and Membranes Guidance Manuals for LT2 • IDSE Guidance Manual • Simultaneous Compliance Guide for LT2 and Stage 2 • Training on using EPA’s Data Collection and Tracking System online

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