Proposed Long Term 2 Enhanced Surface Water Treatment Rule

1. Proposed Long Term 2 Enhanced Surface Water Treatment Rule

2. 2 Agenda for LT2ESWTR Presentation Overview of the LT2ESWTR Cryptosporidium Monitoring and Implementation Details Related Q&A Microbial Toolbox Other rule requirements Related Q&A

3. Overview of the LT2ESWSTR

4. 4 Applicability and Purpose Applies to all systems using surface water or ground water under the direct influence of surface water Supplements existing regulations by focusing on Cryptosporidium in systems with higher risk Filtered systems with high source water occurrence All unfiltered systems Maintains microbial protection while systems address health risks from disinfection byproducts

5. 5 Existing Regulations IESWTR and LT1ESWTR Require 2-log (99%) removal of Cryptosporidium in all filtered systems Do not require treatment for Cryptosporidium in unfiltered systems, except through watershed control Do not require existing finished water reservoirs to be covered

6. 6 New Data on Cryptosporidium Occurrence Source water occurrence overall is lower than previously thought However, relatively high levels in some filtered systems Finished water occurrence typically higher in unfiltered systems Infectivity greater than previously estimated Effectiveness of treatment technologies including UV light and ozone

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8. 8 Source Water Monitoring at Large Filtered Systems (?10,000 People) Sample for Cryptosporidium, E. coli, and turbidity for 24 months Two options for sampling frequency Monthly OR Semi-monthly (or more frequent) Second round of monitoring six years after bin classification Exempt if system provides at least 5.5 log Cryptosporidium treatment

9. 9 Bin Classification for Large Filtered Systems Determination of bin assignment depends on number of samples taken For systems conducting monthly sampling, calculate running annual averages (RAAs) for Cryptosporidium and use the highest of these averages For systems conducting semi-monthly (or more frequent) monitoring, calculate the mean concentration of all 48 (or more) samples

10. 10 Filtered System Bin Classification and Treatment

11. 11 Filtered System Bin Classification and Treatment Treatment requirements listed in table apply to systems using conventional, slow sand, or diatomaceous earth filtration Based on assumption of 3 log average removal Direct filtration systems must provide an additional 0.5 log Cryptosporidium treatment for Bins 2-4 (i.e., 1.5, 2.5, and 3.0 log) Alternative filtration systems must provide total Cryptosporidium treatment of 4.0, 5.0, and 5.5 log in Bins 2-4 as determined by State

12. 12 Source Water Monitoring at Small Filtered Systems (<10,000 People) Initial E. coli screening analysis to determine if Cryptosporidium monitoring is required Bi-weekly E. coli sampling for one year If mean E. coli exceeds trigger value, then semi-monthly Cryptosporidium sampling for one year Mean E. coli > 10/100 mL for lake/reservoir sources Mean E. coli > 50/100 mL for flowing stream sources Bin classification based on mean Cryptosporidium concentration Systems below E. coli trigger levels incur no additional monitoring or treatment requirements

13. 13 Source Water Monitoring at Unfiltered Systems Large systems monitor Cryptosporidium at least monthly for 24 months All small systems monitor Cryptosporidium semi-monthly for 12 months E. coli and turbidity monitoring not required Exempt if system currently provides at least 3 log Cryptosporidium inactivation

14. 14 Treatment by Unfiltered Systems All unfiltered systems must provide Cryptosporidium inactivation If mean Cryptosporidium concentration is >0.01 oocysts/L, systems must provide at least 3 log Cryptosporidium inactivation Otherwise must provide at least 2 log Cryptosporidium inactivation Must use chlorine dioxide, ozone, or UV for Cryptosporidium inactivation Must use two disinfectants for overall Cryptosporidium, Giardia, and virus inactivation

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16. 16 Estimated Impact of Rule Total annual costs for systems and States are estimated at $73 to 111 million Up to 35 percent of systems are projected to add treatment Mean annual household costs are $1.07 to $1.68 For households in systems adding treatment, median annual cost increase is $3.23 Benefits estimated as 260,000 to 1,020,000 cases of cryptosporidiosis avoided annually From 37 to 141 associated deaths avoided

17. Cryptosporidium Monitoring and Implementation Details

18. 18 Monitoring Schedule Submit sampling schedule 3 months before beginning monitoring Schedule must specify calendar dates when each sample will be collected Calendar dates may vary a little from month to month Collect sample within 2 days of the dates on the schedule If system cannot sample on scheduled date due to dangerous or unforeseen conditions, then sample as close to date as feasible If method requirements are violated, then collect replacement sample within 14 days of notification

19. 19 Analytical Method for Cryptosporidium EPA Method 1622 or 1623 Sample volume analyzed must be at least 10 L or packed pellet volume of at least 2 mL or volume passed through 2 filters QC criteria include analysis of matrix spike samples initially and after every 20 samples from a given plant Labs must be certified by EPA or equivalent State program

20. 20 Calculation of Sample Concentration Individual sample concentrations based on total number of oocysts counted in each sample (unadjusted for recovery), including empty oocysts and other oocysts that may not be viable In samples where no oocysts are detected, concentrations are assigned a value of 0 oocysts/L

21. 21 Example Calculation of Bin Classification Applies to large filtered systems monitoring monthly Calculate RAA for months 1-12 (0+0+0.1+0.1+0.2+0.1+0.1+0+0+0+0+0)/12 = 0.05 Determine RAAs for months 2-13, 3-14, 4-15 ...

22. 22 Example Calculation for Bin Classification (cont.) Determine maximum of all RAAs Maximum annual average concentration is 0.075 oocysts/L System is classified in Bin 2 (1 log additional treatment for conventional plant)

23. 23 Sampling Location Requirements Samples must be taken at intake prior to any treatment, except as described below Systems that add chemicals at intake must sample as close to intake as possible, at similar depth and distance Special directions for systems using bank filtration, off-stream storage, presedimentation, or multiple sources

24. 24 Source Water Sampling Location for Bank Filtration Processes

25. 25 Source Water Sampling for Raw Water Storage or Presedimentation Processes

26. 26 Source Water Sampling for Multiple Sources Must sample where the sources are combined, if sample tap is available If combined source tap is not available then sample each source separately and determine a weighted average concentration using one of two methods (see next slide)

27. 27 Sampling for Multiple Sources Separately

28. 28 Grandfathering Monitoring Data for Bin Classification Existing Cryptosporidium data may be used for bin classification if approved by EPA Data must meet same conditions as data collected under LT2ESWTR (i.e., same method, sampling frequency, sampling location, volume analyzed) Systems with less than 2 years of existing data may use these data for bin classification but must conduct additional monitoring until they have a total of 2 years of data

29. 29 Implementation Support Large systems will report initial sampling schedule and monitoring results to EPA Data system for electronic reporting and review of monitoring results States will have full access to their systems� data Guidance manuals and help line will address sampling and analysis questions Draft guidance available with proposal Results from small system and from 2nd round of monitoring will be reported to States Ongoing EPA laboratory certification program for Cryptosporidium analysis

30. 30 Related State Requirements Records Kept by States Monitoring results and bin classification Cryptosporidium treatment measures Reports by States to EPA Bin classification for each system Special Primacy Conditions How States will assess significant changes in source water as part of sanitary survey

31. 31 Requests for Comment Monitoring requirements for systems that use surface water for only part of the year Grandfathering monitoring data that do not meet acceptance criteria Monitoring for systems recycling filter backwash Monitoring for new plants and sources Treatment requirements for unfiltered systems with higher Cryptosporidium levels See proposal for details and other issues

32. Questions?

33. Microbial Toolbox

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35. 35 Source Toolbox Options

36. 36 Pre-Filtration Toolbox Options

37. 37 Treatment Performance Toolbox Options

38. 38 Additional Filtration Toolbox Options

39. 39 Additional Filtration Toolbox Options (cont.)

40. 40 Inactivation Toolbox Options

41. 41 Additional Requirements for Unfiltered Systems Systems using chlorine dioxide or ozone may not fail to achieve required Cryptosporidium inactivation more than one day a month Systems using UV must meet required Cryptosporidium inactivation for at least 95 percent of water delivered to public each month

42. Other Rule Requirements

43. 43 Uncovered Finished Water Reservoirs Compliance options (to be in place 36 months after promulgation) Cover Treat to achieve at least 4 log virus inactivation Implement State-approved risk mitigation plan addressing access and site security, surface water runoff, animal waste, and ongoing water quality assessment

44. 44 Disinfection Profiling and Benchmarking Systems must monitor weekly for 12 months during peak hourly flow to determine Giardia and virus inactivation profiles Existing profiles and historical operational data may be used if disinfection practices have not changed Transient noncommunity systems are exempt Small systems may be exempt based on disinfection byproduct levels and E. coli monitoring

45. 45 Disinfection Profiling and Benchmarking (cont.) Systems that plan to make a significant change in their disinfection practice must calculate a disinfection benchmark (from data collected during profiling) and notify State Benchmarks are defined as the lowest mean monthly values of Giardia and virus inactivation

46. 46 Related State Requirements Records Kept by States Systems required to cover or treat uncovered finished water reservoirs and systems with risk mitigation plans Special Primacy Conditions Approval of watershed control programs Approval of �demonstration of performance� protocols Approval of risk mitigation plans

47. 47 Related Requests for Comments For each microbial toolbox option: (1) Whether data support proposed credit and design/implementation criteria and (2) additional data on treatment effectiveness For uncovered finished water reservoirs: alternatives to covering, including Cryptosporidium and Giardia inactivation, and how to define a finished water reservoir

48. 48 How to Submit Comments See the proposal (68 FR 47640, August 11, 2003) for directions on submitting comments electronically, by mail, or by hand delivery. Comments must be submitted to EPA�s Docket Supporting technical analyses can be acquired through EPA�s Docket see http://www.epa.gov/edocket/ The 150 day public comment period for the LT2ESWTR ends January 9, 2004.

49. Questions?