Long Term 2 (LT2) Enhanced Surface Water Treatment Rule TCEQ Environmental Trade Fair May 2015
Dec 23, 2015
Long Term 2 (LT2) Enhanced Surface Water Treatment Rule
TCEQ
Environmental Trade Fair
May 2015
Surface Water
• Serves majority of people in U.S.• Source for most large systems in Texas• Especially vulnerable to microbial
contamination• Cryptosporidium, E. coli, and Giardia
lamblia present in most surface water• Series of regulations addresses
heightened risk
Surface Water Treatment Rules Summary
• All Subpart H systems• Reduce risks from Giardia lamblia & viruses
SWTR (1989)
• Subpart H systems serving > 10,000• Address Crypto with improved treatment
IESWTR (1998)
• Requirements similar to IESWTR applied to Subpart H systems serving < 10,000
LT1ESWTR (2002)
• All Subpart H systems• Target additional treatment at highest-risk
systems
LT2ESWTR (2006)
Subpart H Sources
• Surface Water – rivers, lakes, reservoirs, canals, etc.
• Ground Water Under the Direct Influence of Surface Water (GUI)
• Rainwater Collection Systems
What is Cryptosporidium?
• Protozoan parasite that lives and reproduces in one host
• Transmission• Contaminated food or water• Direct contact with feces• Direct or indirect contact with sick
individuals• Oocysts are very small: 4-5 microns• Can survive for months without a host
Cryptosporidium (Crypto)
• Resistant to traditional disinfectants such as free chlorine
• Can pass through some filters due to small size
• Typical filtration treatment techniques and alternative disinfectants (Chlorine Dioxide, Ozone, UV) can remove and/or inactivate Crypto
Health Effects of Cryptosporidium
• Causes cryptosporidiosis• Mild to sever diarrhea, dehydration,
stomach cramps, and slight fever• Immunocompromised individuals can die
from infection• No known cure for cryptosporidiosis
Outbreaks
Location Number of Cases Year
Carroll County, GA 13,000 1987
Milwaukee, WI 403,000 1993
Clark County, NV 101 1993-94
Baker County, OR 119 2013
Cryptosporidiosis Outbreaks in U.S. Municipal Water Supplies
Purpose of the LT2ESWTR
• Improve public health protection for surface water, GUI, and rainwater systems• Reduce illness caused by Crypto and
other microorganisms• Tailor requirements based on:
• Level of treatment• Source water quality• Water system size
• Provide system with flexibility
LT2ESWTR Overview
• Source water monitoring• Screening procedure for small
systems• Target treatment for highest-risk
systems• Additional treatment expected to be
the exception instead of the rule
LT2ESWTR Process
Systems Subject to LT2
Initial Round Source Water Monitoring
Bin Classification
Choose Toolbox Option(s)
Implement Tool(s)
Second Round Source Water Monitoring
Systems installing
max treatment
Bin 1 systems
Small systems w/ low E. coli
2
1
3
4
5
0
Round 2 Start-up Package for Monitoring Plans
Sent out to systems prior to sampling start dates and includes:• Sampling requirements• Sampling location worksheet• Sampling location schematics• Sampling schedules for Crypto and
E. coli
Single Source Sample Location
LT2 Sample
point
Backwash water recycle(if applicable)
Water Treatment plant
Source water
Chemicaladdition
Backwash water recycle(if applicable)
Raw water intake
Raw water chemical building
LT2 Sample
point
Multiple Sources Sample Location
Raw water blending station
Raw water intake
Chemical addition
Source water “B”
Source water “A”
LT2 Sample
point
Backwash water recycle(if applicable)
Water Treatment plant
Round 2 SchedulesPublic Water System Classification Schedule
and Start Date
System serving 100,000 or more people OR a wholesale system in a CDS that contains a system serving >100,000
1April 1, 2015
System serving 50,000 to 99,999 people OR a wholesale system in a CDS that contains a system serving 50,000 to 99,999
2October 1,
2015
System serving 10,000 to 49,999 people OR a wholesale system in a CDS that contains a system serving 10,000 to 49,999
3October 1,
2016
System serving fewer than 10,000 and not a wholesale system
4October 1,
2017
Combined Distribution Systems
• The Combined Distribution System (CDS) requirements only apply to systems (wholesalers) that provide (not necessarily sell) water to at least one other PWS
• Monitoring requirements are based on the population of the largest water system in a CDS
Source Water Monitoring Round 2: Schedules 1-3
24 samples plus two matrix spikes required for:• Cryptosporidium
• Select an EPA certified lab to conduct Crypto analysis
• E. coli• Select a NELAP certified lab to conduct analysis
with the approved enumeration method
• Turbidity• Conduct turbidity analysis at your own treatment
plant
Source Water Monitoring Round 2: Schedules 1-3
• Matrix spike samples for the 1st and 13th sample
• Collect samples within a two-day window on either side of the dates specified in LT2 monitoring plan
• Send individual sampling results to the LT2 Program by email at [email protected], by facsimile at 512-239-6050, or by correspondence at:
LT2 Program
TCEQ Public Drinking Water Section – MC 155
PO Box 13087
Austin, TX 78711-3087
Source Water Monitoring Round 2: Schedule 4
• Option to monitor for e. coli instead of Cryptosporidium
• Collect one sample every 2 weeks for 12 months (26 samples total)
• Cryptosporidium monitoring is triggered if a 12 month running average exceeds 100 colony forming units (CFU) per 100 mL
Source Water Monitoring Round 2: Schedule 4
• Cryptosporidium Monitoring Options• Once per month for 24 months• Twice per month for 12 months
• Samples still must be equally spaced over the 12 or 24 month period
Treatment Options
• Water systems can opt out of source water monitoring• Provide 5.5-log removal/inactivation of Crypto
at ALL times• Need to prove the 5.5-log removal/inactivation
by a Demonstration of Performance
• Also, is source water monitoring is indicating a Bin 4 level of treatment, system can stop monitoring and agree to provide full treatment
Treatment Options
• Consider before choosing treatment:• Currently most systems in Texas are
classified as Bin 1 in Texas
• There are 9 PWSs (10 plants) classified as Bin 2 systems and required to provide additional treatment at their plants
• Full treatment option may be a viable option if you already provide “Bin 1” filtration and use either ozone or UV (see rule CT tables)
Calculating Bin Concentration
• At the end of testing, TCEQ staff determine the system’s “Bin” level. This will determine the amount of treatment required by the system.
• Crypto testing: For 24 to 27 samples, TCEQ calculates the average concentration for every rolling 12 month period and selects the highest average.
• E. coli testing: Calculate the average concentration for all samples.
Bin Classification
• Water systems serving less than 10,000 people which only monitored for E. coli are automatically placed into Bin 1
• Does not include small systems which triggered Crypto sampling by having an E. coli average greater than 100 MPN/100mL
Levels of Additional Treatment
Average Cryptosporidium Level in theRaw Water
Bin ClassificationMinimum
Removal/InactivationRequirement
Cryptosporidium < 0.075 oocysts/L Bin 1 2.0-log
0.075 oocysts/L ≤ Cryptosporidium < 1.0oocysts/L
Bin 2 4.0-log
1.0 oocysts/L ≤ Cryptosporidium < 3.0oocysts/L
Bin 3 5.0-log
Cryptosporidium ≥ 3.0 oocysts/L Bin 4 5.5-log
Crypto Removal Credits
• Treatment plants using coagulation, flocculation, and granular media filtration receive 2,5-log Crypto removal credit.
• Treatment plants using coagulation, flocculation, clarification, and granular media filtration receive 3.0-log Crypto removal credit.
• TCEQ assigns Crypto removal credit to treatment plants using bag, cartridge, or membrane filters on an individual basis.
Microbial Toolbox Options
1. Watershed control program
2. Alternative source
3. Pre-sedimentation basin with coagulation
4. Two-stage lime softening
5. Bank filtration
6. Combined Filter (CFE) Performance
7. Individual Filter (IFE) Performance
8. Demonstration of Performance
Microbial Toolbox Options
9. Bag or Cartridge Filters (individual filters)
10. Bag or Cartridge Filters (in series)
11. Membrane Filtration
12. Second stage Filtration
13. Slow sand Filters
14. Chlorine dioxide
15. Ozone
16. Ultraviolet (UV)
Treatment Compliance Deadlines
Population Served
Must comply with Crypto treatment requirements no later
than…
100,000 or more April 1, 2021
50,000 to 99,999 October 1, 2021
10,000 to 49,999 October 1, 2022
Less than 10,000 October 1, 2023
Treatment Compliance Deadlines
• States may allow up to an additional two years for complying with treatment requirements for systems making capital improvements
QUESTIONS?
Tamira Konkin-Garcia
(512) 239-1298
Sean Ables, P.G.
(512) 239-1758