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LT2 & Stage 2 Compliance taking the right steps at the right time ( part 1 of 2)

LT2 & Stage 2 Compliance taking the right steps at the right time ( part 1 of 2). Jan C. Routt Jan Routt & Associates, LLC 3636 Timberwood Lane Lexington, KY 40515 859-971-0858 office 859-537-7750 mobile jroutt@alltel.net email Janroutt.com website. LT2 Plan or bin classification due.

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LT2 & Stage 2 Compliance taking the right steps at the right time ( part 1 of 2)

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  1. LT2 & Stage 2 Compliancetaking the right steps at the right time(part 1 of 2) Jan C. Routt Jan Routt & Associates, LLC 3636 Timberwood Lane Lexington, KY 40515 859-971-0858 office 859-537-7750 mobile jroutt@alltel.net email Janroutt.com website

  2. LT2 Plan or bin classification due Stage 2 IDSE Plan or report due LT2 & Stage 2 Implementation Schedule * Graphic adapted from EPA 2009 2010 2012 2013 2006 2007 2008 2011 2014 2015 2016 Possible Extension Crypto monitoring Treatment Installation 1 IDSE Review submission Compliance Possible Extension Crypto monitoring Treatment Installation 2 Review submission IDSE Compliance Crypto monitoring Treatment Installation Possible Extension 3 Review submission IDSE Compliance Compliance (if Crypto Monitoring) Possible Extension E. coli Crypto monitoring 4 Treatment Installation IDSE Review submission Compliance (if no Crypto Monitoring) 2009 2010 2012 2013 2006 2007 2008 2011 2014 2015 2016 * Includes associated consecutive systems

  3. 40 CFR 141.2 New Definitions • Combined distribution system (CDS) – Interconnected distribution system consisting of the distribution system of wholesale systems and consecutive systems that receive finished water. • Consecutive system – PWS that receives some or all of its finished water from one or more wholesale systems. • Wholesale system – PWS that treats source water as necessary to produce finished water and then delivers some or all of that finished water to another PWS. • Finished water – Water introduced into the distribution system of a PWS intended for distribution and consumption without further treatment, except as necessary to maintain water quality in the distribution system.

  4. IDSE/Stage 2 Wholesale System 100,000 Wholesale and Consecutive System 10,000 Consecutive System 50,000 Treatment Plant System A System B System C LT2 R i v e r Treatment Plant LT2 River Subpart H (SW or GWUDI) systems could end up on different schedules for LT2 source monitoring and IDSE/Stage 2 disinfection byproduct monitoring and treatment implementation Adapted from EPA

  5. LT2 –SW & GWUDI source testing and treatment • Source Crypto levels to be tested • Establish schedule & options • Grandfather, test or agree to treat • If source testing is required: • Set up with lab & other staffing resources • Submit schedule & location (deadline for largest systems already passed—consecutive system issues apply) • Electronic monthly reporting to EPA required for all but smallest systems • Remember E.Coli & turbidity testing too. • Treatment to be determined • If more treatment expected –look ahead at Microbial Toolbox options • Optimize existing processes (sources, pre-sed, filtration) • Evaluate alternatives Photos: LWC Cryptosporidium analysis

  6. Siting & Collecting the Samples Photo & Graphics adapted from (LWC & EPA): Source Water Monitoring Guidance Manual for Public Water Systems for Final LT2ESWTR -- Feb 2006 and KY & TN Consecutive System Case Study Scenarios (KYTN WPC July 2006) • Locate the sample site appropriately • Upstream of chemicals or recycle • Consider multiple sources, seasonal sources • Sample collection • (on scheduled date + or- 2 days) • 10-plus liters of water transported to lab • Or sampler filters 10-plus liters • Reality Check—practice

  7. Calculating Crypto Levels & LT2 Bin Assignments One crypto detect can make the Bin/Treatment -> $$$ • >0.075 oocyst/L = Bin 2 (more treatment required) • Treatment (Toolbox) options interim and long term • Optimize filtered turbidity using Partnership for Safe Water Phase III & Phase IV goals Highest 12 month average: 11 non-detects (zeros) plus one detect at 0.85 oocyst/L 0.85/12 months = 0.075 oocysts/Liter BIN 2

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