Jan C. Routt Jan Routt & Associates, LLC KY-TN Joint Water Professionals Conference

1. Systems Working Together to Comply with New LT2/Stage 2 M/DBPRs KY & TN Wholesale and Consecutive System Case Study Scenarios* Jan C. Routt Jan Routt & Associates, LLC KY-TN Joint Water Professionals Conference Chattanooga, Tennessee July 10, 2006 *adapted from original presentation, photos omitted for web posting.

2. WE ARE HERE LT2 Plan or bin classification due Stage 2 IDSE Plan or report due Implementation Schedule * 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 IDSE Review submission Treatment Installation 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. Combined Distribution Systems 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 Combined Distribution System 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

5. LT2 ESWTR Surface Source Water Microbials Cryptosporidium, E.Coli and Turbidity 2 years monthly testing to determine source treatment requirements, Testing cost ~ $25,000-$40,000 per source “grandfather” acceptable data, or Agree to provide full treatment

6. LT2 Source Monitoring CDS Requirements– 1 year monthly Crypto/E.Coli/Turbidity sampling • Only applies to surface water/GUDI systems • Population of largest system receiving water determines LT2 source monitoring schedule. • If buying water, or considering buying water, from a SW provider, advisable to inquire as to LT2 monitoring and treatment status. • Treatment Technique compliance criteria & tracking not yet clearly established • Systems providing water to large combined systems via current or planned advanced treatment processes may want to go ahead with bin testing rather than agreeing to provide maximum treatment to avoid monitoring • Cost of PN for future TT violation in case of treatment failure would be substantial

7. Trihalomethanes & Haloacetic Acid5 – 1 year testing at multiple new sites every 60 – 90 days Number samples based on system population Entry, Average and Maximum formation sites ~$15,000-$85,000 added testing costs for one year Stage 1 testing & compliance continues based on system average through 2011 at least Stage 2 Disinfection Byproducts RuleDistribution System MonitoringInitial Distribution System Evaluation IDSE  Stage 2

8. Stage2/IDSE CDS multiple samples per 60 or 90 days for 1 year in addition to Stage 1 Wholesale System 100,000 Consecutive System 10,000 Consecutive System 50,000 Treatment Plant System A System B System C R i v e r Treatment Plant River Combined Distribution System IDSE/Stage 2

9. 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

10. 141.600 IDSE/Stage 2 Distribution Disinfection Byproducts --General Requirements • Purpose of IDSEs: • Determine locations of high TTHM and HAA5 concentrations throughout distribution system • Results are used in conjunction with Stage 1 DBPR compliance monitoring to identify and select Stage 2 DBPR compliance monitoring locations (used for LRAA effective 2012 or later) • Every PWS must perform separate IDSE and Report • Stage 2 sampling may go back to combined system—minimum of 1 sample per system

11. Stage 2 DBPR IDSE Options 1 3 4 2 VSS Waiver 40/30 Certification Standard Monitoring System Specific Study Stage 1 continues Existing &/or New Data May Apply Choose Stage 2 TTHM/HAA5 Sites for Compliance Conduct Stage 2 Compliance Monitoring LRAA

12. Stage 2 DBPR NO IDSE Prior data 1.5 x SMP IDSE Options Model 0.2 x SMP 1 3 4 2 Standard Monitoring VSS Waiver 40/30 Certification System Specific Study Stage 1 continues Existing &/or New Data May Apply Choose Stage 2 TTHM/HAA5 Sites for Compliance Conduct Stage 2 Compliance Monitoring LRAA

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

14. Challenges for Consecutive Systems • Receive water that has already been treated • May contain DBPs • May contain high levels of precursors and disinfectants • BATs for systems with their own source focus on precursor removal • Not an option for consecutive systems • Stage 2 DBPR introduces new BATs for consecutive systems • Management of distribution system and storage • Chloramination • Consecutives and wholesalers work together for best alternatives

15. Challenges for Consecutive Systems • States have taken different approaches in past • May lack data to determine appropriate monitoring locations for Stage 2 DBPR • May not be eligible for VSS Waiver or 40/30 Certification under IDSE if lacking data • Would need to do Standard Monitoring or SSS • Work with wholesaler • May have taken samples in consecutive system’s distribution system • System-specific/state-specific regulatory interpretations may apply

16. Tennessee Regulatory Overview & Case Study Examples

17. Tennessee Stage 1 Regulations & Case Study Examples • Consecutives in combined systems have been included in compliance DBP monitoring and calculations since 1999 • All systems required to test since 2004--except where small systems are surrounded by larger systems (ex. apartment systems) • <500 population systems are encouraged to monitor this summer to qualify for VSS waiver. • No chloramines allowed in Tennessee to date. • Many systems are in compliance using optimized treatment with alternate in-plant pre-filter disinfection (H2O2, enhanced coagulation, P-carbon, G-carbon) • Some large systems will qualify for 40/30 certification TDEC ConactRobert.Foster@state.tn.us TDEC ConactRobert.Foster@state.tn.us

18. Tennessee on the New Regs TDEC Contact: Robert.Foster@state.tn.us • Most TN ground water systems and even some large subpart H systems will qualify for the 40/30 certification. (One TN field office was already issuing 40/30 certifications in April 06.) • Systems need to be aware that IDSE System Specific Studies (Modeling or prior DBP data) will be reviewed by the EPA and not the states. • Tennessee will expect combined distribution systems to coordinate sampling, so that, for the most part, everyone samples on the same days in order to make the data comparable. • Systems encouraged to work closely with the state laboratory certification officers to minimize errors inherent to method 555.2 used for haloacetic acids. See the August 18, 2003 table V-19 Federal Register proposals for details. Surrogate recoveries and other factors need to be looked at in regard to lab results.

19. Tennessee on the New Regs TDEC Contact: Robert.Foster@state.tn.us • Systems need to be aware that they should sample early in the compliance period, and insist on analytical results as soon as possible, so that the system can collect additional samples to address abnormally high, or questionable, analytical results before compliance period ends. • Systems need to be aware that Stage 2 Rules revise the Stage 1 Rules to require TOC sampling at plants using non-conventional filtration to qualify for reduced monitoring.

20. Tennessee on the New Regs TDEC Contact: Robert.Foster@state.tn.us • Because many systems will have to conduct public notice, the health effects issues discussed by the EPA on page 405 and 406 of the January 2006 Federal Register in regard to colon and rectal cancers and negative reproductive outcomes could be included in the public notices to better inform customers of systems with MCL violations.

21. Nontraditional water systems Nashville Water Department West Wilson W.D. Brentwood Water Dept. “Non-Traditional Water Systems” -Property Owners -MHP Total in CDS: 62 Source: SDWIS and TN DWS, (compiled by R-IV EPA)

22. Safe Drinking Water Query Form for the State of Tennessee Query Form Search the SDWIS Database http://www.epa.gov/enviro/html/sdwis/sdwis_query.html \ Query Form Search the SDWIS Database One County – 89 pubic water supplies

23. 4 water providers; 85 purchasers

24. 4 water providers; 85 purchasers over 500 population –to do IDSE on schedule of largest wholesaler Less than 500 population may qualify for Very Small System Waiver if have TTHM/HAA5 data –— May need to sample this summer…. contact TDEC for more information

25. 34 systems <500 population may qualify for VSS Waiver with DBP results

26. Knoxville Utilities Water System • Large wholesaling SW System (population 190,324) • Low TOC source (Tennessee River) • Bin 1 Crypto—with “grandfather-able” data • Conventional clarification treatment, chlorine dioxide/free chlorine • One consecutive with multiple wholesalers • Other wholesalers have 40/30 Certifications • All assigned to same Schedule 1 CDS

27. W3 (JC) W2 (NM) KUB W1 CS1 (SG) CS2 (DD) W3 (SV) W4 (NP)

28. Knoxville DBP history -> LT2/Stage 2 IDSE • Free chlorinated system—close to 40/30 • Max month September – DBPs sampled in special studies • Using fluoride tracers to measure retention time & select SMP IDSE sites • automatically monitored – fluoride probes configured with data loggers • time for non-fluoride treated water to reach points in system to track water retention time • Studies to extend into consecutive system

29. Summary of KUB Fluoride Tracer Studies -- Setup & Results • Six probes and data loggers • Four separate testing events to-date • North, South, East & West system areas • Sites selected from hydraulic model and general system knowledge • Track time for fluoride level changes • drop after shutting off fluoride at plant • return after turning back on at plant • Very Interesting findings– an excellent tool. • Making distribution operational changes based on test findings • Additional studies planned • Repeat all tracer tests (as time allows prior to IDSE plan deadline) • Longer holding-time SDS for comparison

30. Kentucky Regulations & Case Study Examples

31. Kentucky Regulations & Case Study Examples • Consecutives in combined systems have been included in Stage 1 compliance monitoring and compliance tabulations of the combined systems (wholesaler and purchaser) since 1990. • Pre-chlorination has been required for most part • Few chloraminating systems (larger, some seasonal) • State guidance for moving point of chlorination and for conversion to chloramines

32. CombinedConsecutive Systems have “joint” responsibility for DBP formation and control (under current KY regs) Buyer, purchaser, Consecutive Seller, producer, Wholesaler • THM/HAA compliance = average of four sites per “joint” (or combined) system

33. Wholesaler C (>10K): GW & free chlorine Wholesaler D (<10K): GW & free chlorine Consecutive B(<10K): purchased & rechlorinated Wholesaler A(<10K): SW free chlorine or chloramine seasonal, variable Wholesaler F(>50K <100K) SW & chloramines; yearly brief free chlorination Wholesaler G(>100) SW & chloramines) yearly brief free chlorination. Breakpoint free chlorinated as needed @ Consec B’s master meter for nitrification control. Wholesaler E (>10K,<50K) SW & chloramines, no yearly free chlorination; water may be purchased from supplier F or G.

34. Some systems are already meeting LRAAs (ground water and chloraminating systems) and others have a way to go. Intermittent supply connections <50K >50K >100K Chloramines Free chlorine

35. Average Yearly THM & HAALevels 0.16 0.14 Coagulation pH Alum at high pH 0.12 Lowered/Raised Ferric Chloride 0.1 THMs/HAAs (mg/l) Ferric PACL 0.08 0.06 0.04 0.02 0 1980 1984 1988 1992 1996 2000 Even large (>300K) system (including multiple consecutives) in compliance using pre-filter Chorine, optimized coagulation and distribution Chloramines Pre-Chlorine dioxide Intermediate chlorination Partnership Turbidity Optimization Chloramines EVEN LRAAs Chloramines Distribution Free Chlorine 2004 Increased # max sample points Decreased # max sample points

36. Free Chlorinated System DBPS • Wholesaling systems need to be optimized according to Stage 1 requirements and guidance –prior to chloramine conversion • State approvals, benchmarking required prior to change impacting treatment CT • Distribution retention time must be managed • Go to the max site LRAA if you want to know what the future holds

37. Continuous, relatively small volume connections START DATE FOR MONITORING AND COMPLIANCE—DETERMINED BY LARGEST POPULATION SYSTEM IN A COMBINED SYSTEM. States may use knowledge of system to decide whether a smaller system is considered consecutive of the larger for this purpose of IDSE/S2 scheduling . Intermittent supply connections <50K >50K >100K

38. How many samples…when? 24 Systems: (>100Klargest): IDSE 252 --> 54 Stage 2 ISDE site plans due 6 months after promulgation Where the consecutive system lines are drawn has huge implication for smaller systems’ compliance, lab workloads and sample coordination by multiple utilities. <50K >50K >100K <50K

39. For iIlustration purposes only-- All CDS assignments must be verified by KYDOW CDS Schedule 2 (<100K >50K) CDS Schedule 4 (<10K SW &GW) CDS Schedule 34 (<10K SW &GW) <50K >50K >100K <50K CDS : (>100K largest)

40. For iIlustration purposes only-- All CDS assignments must be verified by KYDOW CDS Schedule 4 (<10K SW &GW) CDS Schedule 2 (<100K >50K) CDS Schedule 1: (>100K largest) CDS Schedule 3 (<10K SW &GW) <50K >50K >100K >100K <50K <50K <50K CDS Schedule 1: (>100K largest) CDS Schedule 3 (<10K SW &GW)

41. IDSE Standard Monitoring Plan – Case Study Louisville Water Company & Consecutives • LWC Large Wholesaling (Population 349,000) • Surface Water Source (Ohio River, Moderate TOC) • Two WTPs conventional treatment plus RBI • Chlorine,Chloramines • Multiple Consecutive Systems with multiple wholesalers • 4 separate PWS assigned to LWC CDS • Consecs included in Stage 1 DBP compliance • Contract lab for TTHM & HAA5 testing • LWC conducting IDSEs for consecutives • Coordinated w/LWC IDSE/Stage 2 on Schedule 1

42. LWC W1 CS5 CS1 CS4 CS2 CS3 W4 W3 W6 W2 W5

43. LWC W1 CS1 CS4 CS2 CS3 W3 W2

44. IDSE Plans • Plan must be submitted according by October 1 for Schedule 1 systems to include (Use Forms from IDSE Guidance Manuals-filled in examples are included) • System ID & descriptions • Description of processes to select sites, data summaries used • Sites IDs with justifications—assess available data & sites in context of known hydraulics • Peak Historical Month Basis • Schedule including sampling during max historical month • Schematic – sources, entry points, storage facilities, pressure zones, pumps locations, SMP and Stage 1 Sites (map or schematic scale, minimize use of known landmarks for security) • May review larger, complex systems with State prior to submittal

45. Finding Maximum DBP Month Highest historical = 3rd Quarter (July) • May be selected based on historically highest THMs or HAA5s or water temperature

46. Finding Maximum DBP Month Highest historical DBP = 3rd Quarter (July), Highest temperature = Aug • May be selected based on historically highest THMs or HAA5s or water temperature • Other factors may come into play as well… TOC, pH, hydraulics or treatment changes

47. Stage 1 & IDSE Scheduling

48. Stage 1 & IDSE Scheduling

49. Stage 1 & IDSE Scheduling

50. Stage 1 & IDSE Scheduling