Regulatory Review Presented by: Joe Munson

1. Regulatory Review Presented by: Joe Munson

2. Outline • New Employee/Office • Lead and Copper Reminder • Stage 2 Disinfection Byproduct Rule

3. New Employee • Patty Krein is the new Drinking Water Secretary. • Drinking Water has a new office location in Sioux Falls. Phone: 362-3521.

4. Lead and Copper Reminder • If your EPA ID# > 630. • If you are scheduled to sample for Pb and Cu every three years. • Then you have until September 30 to collect your Pb and Cu samples.

5. Stage 2 Disinfection Byproduct Rule (DBPR) Will apply to all community and nontransient noncommunity water systems that add a chemical disinfectant or that purchase water with an added chemical disinfectant. 403 systems in South Dakota will have to comply with Stage 2 regulations.

6. Initial DistributionSystem Evaluation (IDSE) Options • Very Small System Waiver (VSS) • 40/30 Certification • Standard Monitoring Plan (SM) • System Specific Study (SSS)

7. IDSE Implementation Timeline Schedule for systems in a combined distribution system is based on that of the largest system in the combined distribution system

8. Very Small System (VSS) Waiver

9. Eligibility Criteria • Systems must • Serve fewer than 500 people • Have taken TTHM and HAA5 samples • Reduced monitoring acceptable • Operational data acceptable • 137 systems out of an eligible 243 systems in South Dakota have received their VSS Waiver • Note: EPA or the state may deny a VSS Waiver for any reason, even if system meets all eligibility criteria

10. VSS Waivers • Waivers effective immediately • No application necessary • Systems must meet all criteria • EPA or the state can require Standard Monitoring or System Specific Study • VSS Waiver is only a waiver from additional IDSE activities • No Standard Monitoring or System Specific Study Plan • No IDSE Report • Continue compliance with Stage 1 DBPR until Stage 2 DBPR compliance begins • Complete a monitoring plan for the Stage 2 DBPR

11. 40/30 Certification

12. Eligibility Criteria • Systems must have Stage 1 DBPR data or data equivalent to eight quarters worth of sampling: • No individual sample can have exceeded: • 0.040 mg/L for TTHM • 0.030 mg/L for HAA5 • No TTHM or HAA5 monitoring violations • For schedule 3 and 4 systems data can not be before January 1, 2005 • Approximately 88 systems in South Dakota will be eligible for a 40/30 Certification • Note: EPA or the state may deny the certification for any reason, even if system meets all eligibility criteria

13. Operational Data • EPA or the state may allow systems to use operational data to qualify for 40/30 certification. • Data must be equivalent to Stage 1 DBPR data. • Samples must be taken and analyzed by approved methods at a certified lab. • Adequate number of sample sites for system size. • Samples must be taken at appropriate locations (average or maximum residence times). • Samples must be taken at appropriate frequency and during the month of warmest water temperature.

14. Submitting a 40/30 Letter • Once a system has collected a sufficient amount of data it can prepare a 40/30 Certification Letter and submit it to the EPA: • Electronically (through EPA’s DCTS) • Hard-copy (through mail) • US EPA-IPMC PO Box 98 Dayton, OH 45401-0098

15. Example 40/30 Certification Letter System Information PWS Name_____________________ PWS ID:_______________________ Street Address:__________________ City, State, Zip:_________________ Population Served:_______________ Source Water Type:  Ground  Subpart H System Type:  CWS  NTNCWS Combined Distribution System:  Wholesale  Consecutive  Neither Contact Person Name: _______________________Title: ____________________ Phone Number:__________________Fax Number (if available):____________ Email Address (if available):_______________________ Certification I hereby certify that each individual Stage 1 DBPR compliance sample collected from ________ to _______ was less than or equal to 0.040 mg/L for TTHM and 0.030 mg/L for HAA5. I understand that to be eligible, each individual sample must be equal to or below these values. I also certify that this PWS collected all required Stage 1 samples and did not have any monitoring violations during this time period. Signature:_________________ Date:______________________

16. Standard Monitoring

17. Standard Monitoring Requirements • Population served • Source water type • Justification of Standard Monitoring sites • Distribution system schematic • Entry points, sources, and storage facilities • Locations and dates of proposed Standard Monitoring sites • Locations and dates of Stage 1 DBPR monitoring sites

18. Standard Monitoring Requirements • What, where, and how often do I monitor? • Samples Collected • Dual sample set (both TTHM and HAA5) collected at all locations • Monitoring Locations • High TTHM levels • High HAA5 levels • Average Residence Time • Near Entry Points • Number of sites • Based on system’s source water type and population served • Monitoring Frequency • 1, 4, or 6 monitoring periods during the year at each location • Number based on population served and source type

19. TTHM and HAA5 Standard Monitoring(1) • For groundwater systems or systems that purchase groundwater (1) A dual sample set (i.e., a TTHM and an HAA5 sample) must be taken at each monitoring location during each monitoring period. (2) The peak historical month is the month with the highest TTHM or HAA5 levels or warmest water temperature.

20. TTHM and HAA5 Standard Monitoring(1) • For Subpart H systems and systems that purchase Subpart H water

21. Standard Monitoring Site Selection – Justification • Plan must include a justification for the selection of sites to be sampled during Standard Monitoring • Data sources and tools • Distribution system maps • Water quality data • Distribution system operating data

22. Final “Selected” Sites • Some site selection will be obvious • Near entry point • Others will require professional judgment • Consider geographic representation • Consider hydraulic representation • Consider areas fed by sources with higher DBP precursors • Consider accessibility

23. Submitting Standard Monitoring Plan • Once the system has collected and analyzed its information, it must prepare the plan and submit it to EPA. • Electronically (through EPA’s DCTS ) • Hard-copy (mail to IPMC address) • Must include required information

24. System Specific Study (SSS)

25. Stage 2 Compliance Monitoring Schedule * Date for systems that were required to conduct Crypto monitoring under LT2

26. Questions?