Reducing Disinfection Byproducts through Optimization Webinar #2: Approaches to Prioritize Plant Optimization Efforts April 22, 2019
Reducing Disinfection Byproducts through
Optimization Webinar #2: Approaches to Prioritize Plant Optimization Efforts
April 22, 2019
Webinar Series• Primary Learning Objective: Introduce participants to disinfection
byproduct (DBP) optimization tools that can be used to reduce DBPs in public water systems. These tools have been developed in partnership with state drinking water programs through the Area Wide Optimization Program (AWOP).
• Four successive webinars:• April 8th – DBP Optimization Process and Priority Setting • April 22nd – Approaches to Prioritize Plant Optimization Efforts • May 6th – Approaches to Prioritize Distribution System Optimization Efforts• May 13th – Implementation of DBP Control Strategies: Approach and Case Studies
Webinar Series Logistics• All webinars will be scheduled for 1:30 pm ET, will take about 2 hours
(including Q&A), and will be recorded.• Register for EACH webinar individually through ASDWA.• Viewers can submit questions via the Questions Panel at any time during
the broadcast, but we encourage you to do so as soon as the question comes to mind. A Q&A session will be held at the end of all the presentations.
Webinar #2: Learning Objectives• Understand overall approach for the webinar series, including a brief review
of information covered in the previous webinar• Understand approaches and tools used to prioritize available plant-based
DBP control strategies• Historical water quality data needed to prioritize strategies (Presentation 2)• Surrogate DBP monitoring tool to enhance DBP optimization efforts (Presentation 3)• Studies that can help assess potential for, and impact of, implementing DBP control
strategies in a treatment plant (Presentation 4)
Disclaimer
The information in this presentation has been reviewed and approved for public dissemination in accordance with U.S. Environmental Protection Agency (EPA). The views expressed in this presentation are those of the author(s) and do not necessarily represent the views or policies of the Agency. Any mention of trade names or commercial products does not constitute EPA endorsement or recommendation for use.
Process to Reduce DBPs through Optimization
Review
Process to Reduce DBPs through Optimization
Note: in-plant optimization efforts can be effective for both HAA5 and TTHM reduction, while distribution system (DS) optimization efforts will generally only reduce TTHM levels.
Updated 4/3/19
System is not in compliance with DBP Rule.
Conduct DS influent hold study (duration = system’s MRT).
DS TTHM Optimization
Does the DS influent hold study indicate the bulk water
is very reactive?
YES(start in the plant)
Are plant effluent TTHMs > 30 ppb?
Begin diagnostic monitoring at DS entry point and MRT locations.
NO
In-Plant DBP Optimization
YESNO
(start in the DS)
OPTIONAL
Prioritize, then evaluate in-plant control strategy.
Are TTHMs < plant effluent
goal?
Continue monitoring at EP and compliance locations to assess
performance.
Are there any remaining DS control
strategies?
Optimization is probably not the solution; consider capital
improvements for DBP control.
Prioritize, then evaluate DS control strategy.
Are there any remaining DS control
strategies?
Are TTHMs < MCL?
Are thereany remaining
plant-based control strategies?
Are thereany remaining
plant-based control strategies?
Are TTHMs < MCL?
NO NO
NO NO
NO
NONO
YES
YES
YES
YESYES
YES
System is not in compliance with
DBP Rule.Conduct DS
influent hold study (duration = system’s MRT).
DS TTHM Optimization
Does the DS influent hold study indicate
the bulk water is very reactive?
YES(start in the plant)
Are plant effluent TTHMs > 30 ppb?
Begin diagnostic monitoring at DS entry
point and MRT locations.
NO
In-Plant DBP Optimization
YES
NO(start in the DS)
OPTIONAL
Continue Continue
Diagnosing DBP Formation
First step is to conduct
diagnostic monitoring
System is not in compliance with
DBP Rule.Conduct DS
influent hold study (duration = system’s MRT).
DS TTHM Optimization
Does the DS influent hold study indicate
the bulk water is very reactive?
YES(start in the plant)
Are plant effluent TTHMs > 30 ppb?
Begin diagnostic monitoring at DS entry
point and MRT locations.
NO
In-Plant DBP Optimization
YES
NO(start in the DS)
OPTIONAL
Continue Continue
Diagnosing DBP Formation
Optional step to conduct a DS influent hold
study
Diagnosis Start in the Plant
D• Plant effluent TTHMs > 30 ppb and HAA5 > 20 ppb*• Hold study shows
• The water is very reactive and chlorine decays quickly• MRT TTHM sample > MCL
Treatment optimization to assess oxidation/disinfection and DBP precursor removal
*This is system specific, but based on field experience an optimized plant can likely produce DBPs below this level
Evaluating In-Plant Control Strategies
Focus of Webinar #2• Review of historical
data• DBP surrogate
monitoring to support optimization efforts
• Approaches for evaluating control strategies
Prioritize, then evaluate in-plant control strategy.
Are TTHMs < plant effluent goal?
Continue monitoring at EP and compliance locations to
assess performance.Are there any
remaining DS control strategies?
Optimization is probably not the solution; consider
capital improvements for DBP control.
Prioritize, then evaluate DS control strategy.
Are there any remaining DS control
strategies?
Are TTHMs < MCL?
Are thereany remaining
plant-based control strategies?
Are thereany remaining
plant-based control strategies?
Are TTHMs < MCL?
DS TTHM OptimizationIn-Plant DBP Optimization
NO NO
NO NO
YES
NO
NO
NO
YES
YES
YES
YESYES
YES
Historical Data Review to Prioritize DBP Optimization
Strategies Alison G. Dugan, P.E.
United States Environmental Protection Agency; Office of Ground Water and Drinking WaterStandards and Risk Management Division; Technical Support Center
Pre-oxidant / Dis infectan t
Addit ion
Filt ra t ion
Clearw ell
Coagulant Addit ion
Coag/ Floc/ Sed (TOC Rem oval)
In te rm edia te Dis infectan t
Addit ion
Mainta in CT and Plant Effluent Res idua l
Pos t -Dis infectan tAddit ion
• Oxidation/disinfection• DBP precursor (TOC) removal
Temperature, pH, bromide and NOM composition impact DBP formation but are more difficult to control
Treatment-Based Optimization Options to Reduce DBPs
Example Unintended Consequences of Treatment Control Strategies
Unintended ConsequenceOptimize
Oxidation/ Disinfection
Optimize TOC
Removal Disinfection (CT) and/or DS residual x In-plant bio-growth xChange in quantity/quality of sludge xImpact inorganic oxidation and removal (e.g., Fe, Mn) x x Settled and filtered water turbidity x xImpact on treatment strategy for harmful algal blooms x xImpact corrosion control treatment x xOthers?? x x
Data Review Approach
• Historical water quality data should be reviewed during the process of prioritizing plant based DBP control strategies:
• Ideally, data should be plotted to better identify trends• One-year of data (or more) is best, but a data set that shows
seasonal trends will suffice.
Data Review Approach• Data to consider:
• Total organic carbon (TOC) removal related parameters - raw and treated TOC, coagulant dose & type, coagulation pH
• Disinfection (CT) – including chlorine dose and residual data at all applicable locations
• Water quality data related to other treatment objectives, such as:• Settled and finished turbidity• Inorganic parameters (e.g., bromide, iron, manganese, corrosion-related
others)• Algal toxins• Others?
Flocculation
Sed basins with tube settlers
12 Filters
River Source
Wet well & Pumps
Pumps to Distribution System
Chlorine Addition ClearwellsNaMnO4
Addition
Caustic, Alum, Chlorine added
Caustic Addition
Example Plant Schematic: Treatment Review
Static Mix
•Is enhanced coagulation achieved?•Consider coagulant dose, type and pH:
• Is the dose consistent?• Is a coagulant that is effective for TOC removal used by the system? • Is the coagulation pH in the desired range for TOC removal?
•Other potential treatment strategies (e.g., powdered activated carbon)?
•Treatment objectives that might be impacted (e.g., turbidity removal, corrosion control treatment, etc.)?
Optimize DBP Precursor (TOC) Removal: Data/Treatment Review
Example: Historical TOC-Related Data
Optimize Oxidation/Disinfection: Data/Treatment Review
• Potential locations:• Pre-oxidation (prior to TOC removal/top of filters)• Intermediate or post disinfection (maintain CT and plant effluent residual)
• Review historical data from the WTP to assess the magnitude and trends.• Chlorine dose and residual:
• where and how much chlorine is added? • what are treatment objectives (e.g., CT, Mn removal, biogrowth control, others)?
• CT: where in the plant CT is achieved and at what levels?• Other oxidants: what, where and what dose?
Example:Historical Chlorine Dose Data
Pre = rapid mix and TOF dosePost = post-filter
Example:Historical Chlorine Residual Data
Example: Segment Inactivation (CT) Ratio
Optimize Oxidation/Disinfection:Distribution System Residual Considerations
• Strategy to optimize oxidation/disinfection can potentially impact the plant effluent residual - both level and stability.
• Review historical distribution system residual data to assess whether finished water residual can be lowered, but consider
• Minimum residual requirement (set by primacy agency)• The impact on DBP formation may not be significant• Historical disinfectant residual data may not capture water quality
throughout the entire system
Example:DS Chlorine Residual (based on regulatory monitoring)
Example: DS Chlorine Residual (includes investigative sampling)
0
22
4
Assess Impact on Other Treatment Objectives• Simultaneous compliance means compliance with all existing Safe
Drinking Water Act (SDWA) regulations [SCGM, March 2007]• Example: turbidity may increase due to
• Changing preoxidation • Enhancing TOC removal (i.e., changing coagulation practices, adding PAC) Monitor settled and finished turbidity before and after implementing DBP
control strategies to ensure this is not compromised!
• Confirm simultaneous compliance with other treatment objectives is also maintained.
Summary• Review of historical water quality data is an important step
in prioritizing and evaluating DBP control strategies• Data analysis should support potential DBP control
strategies and identification of possible unintended consequences
• Indicates potential for optimization within the plant• May highlight things to “look out for” during treatment
changes
Questions?Alison Dugan, [email protected], 513-569-7122
In-Plant Monitoring to Assess Disinfection Byproduct FormationAaron Hilborn, P.E.
Arkansas Department of Health
Engineering Section
Characterizing Disinfection Byproduct Formation in a Water Treatment Plant• Disinfection byproduct (DBP) compliance
monitoring occurs in the distribution system (DS), not in the water treatment plant (WTP)
• Additional investigative DBP monitoring may be conducted in a WTP to identify where DBP formation is occuring
• Control strategies may be identified after DBP formation in the treatment process is better understood
Utilizing a Surrogate to Assess THM Formation
• Lab results are typically not available until a few weeks after samples are submitted
• Difficult to assess day-to-day variability of formation• Challenging to make process control changes based on
old data
• Cost of analyzing DBPs is significant, which may make additional monitoring unaffordable
• A surrogate is needed that is relatively low cost, provides immediate results, and can be conducted by operators in a WTP lab
Hach® THM Plus
• Measures THM4 species plus other DBPs• Results are available within one hour• Cannot be used for compliance
monitoring• Collecting paired samples (i.e., THM Plus
and compliance samples) allows a correlation between results from both methods over time
Hach® THM Plus
• Results can be challenging to interpret• Some haloacetic acids interfere at all
concentrations• Other factors may impact results, including
raw and finished water quality, quality control issues, and sample collection practices
• Generally a good process control tool to assess relative trends in THM formation
• One of the most economical field methods available for operators
y = 0.8621x - 19.203R2 = 0.8856
0
10
20
30
40
50
60
70
80
90
100
0 20 40 60 80 100 120
THM Plus (ppb as chloroform)
TTHM
(ppb
)
Tuscaloosa, ALDS Sampling EventMay 9-11, 2006
Safety Factor
Regulatory MCL
Hach® THM Plus vs. EPA Method 501.3
y = 0.3038x + 16.367R2 = 0.1906
0
10
20
30
40
50
60
0 10 20 30 40 50 60 70 80
TTHM Plus (ppb)
TTHM
(ppb
)
Alma, ARPlant Effluent DataMay 2004 thru July 2007
Hach® THM Plus vs. EPA Method 501.3
Sampling and Analysis Considerations
• Careful sample collection • Chlorine demand free amber glass bottles• Filled headspace free• Refrigerate and dechlorinate samples if not
analyzed immediately
• Conduct precision studies to gain confidence in technique
• Read method instructions carefully• Measure chlorine residual when DBP
samples are collected
In-Plant DBP Monitoring Case Studies
Case Study #1: HAA5 and TTHM Monitoring
• Free chlorine, HAA5, and TTHM samples were collected at four locations
• Majority of TTHM formation occurred in sedimentation basin
• HAA5 increased steadily throughout the WTP
• WTP could evaluate if chlorine dose prior to flocculation could be reduced
• HAA5 and TTHM results were available in ≈4 weeks
Case Study #2: THM+ and Disinfection Profile
• Ground Water System in East Central Arkansas
• Challenged with elevated TTHM levels• Utilizes chloramines as a secondary
disinfectant• Conducted three plant profile studies for
THM+, free and total Cl2, free NH3, monochloramine, and temperature
THM+ and Chloramination Profile Study #1
Conducted April 21st, 2015
THM+ and Chloramination Profile Study #1
Conducted April 21st, 2015
Profile Study #1 Observations
• Majority of THM+ formation occurred in aerator and clarifier
• A small dose of chlorine was applied prior to the clarifier
• System had been working with chemical supplier to reduce TTHMs prior to site visit
• System found sedimentation build up in clearwell• Plans were made to clean the following week• In the past, they have found that cleaning their
clearwell has helped reduce TTHMs• System was unaware of naturally occurring
ammonia in their raw water
THM+ and Chloramination Profile Study #2
Conducted June 3rd, 2015
THM+ and Chloramination Profile Study #2
Conducted June 3rd, 2015
Profile Study #2 Observations
• System attempted to form monochloramine prior to sedimentation basins to reduce TTHM formation
• Apparent issues with chloramination process (e.g., inadequate mixing and/or Cl2:NH3-N ratio):
• Free ammonia was not detectable• Considerable difference between total chlorine and
monochloramine results
• Strategy resulted in increased THM+ formation
Case Study #2: THM+ and Chloramination Profile #3
Conducted June 10th, 2015
Case Study #2: THM+ and Chloramination Profile #3
Conducted June 10th, 2015
Profile Study #3 Observations
• System has optimized chloramination process to predominantly form monochloramine
• System initiated an extensive unidirectional flushing program
• Strategy resulted in reduced THM+ formation leaving the WTP and in the distribution system
In-Plant DBP Monitoring Summary• THM Plus is not perfect, but it can be an
effective process monitoring tool• Low-cost surrogate for THM formation that yields
results within an hour• Characterizes relative trends in THM formation• Results become more reliable with experience
• In-plant DBP monitoring can help identify where formation is occuring, so that appropriate control strategies can be evaluated
• Monitoring additional parameters, in addition to THM Plus, can provide useful information
Jackie Logsdon & David MesserDrinking Water Technical Assistance
Department for Environmental Protection
Optimizing a Water Plant to Control DBPs
Overview• Background• Implementation Approach• Optimization Tools• Optimization Implementation & Activities
– Monitoring– Oxidant changes– TOC removal/Jar Testing– Case Study
2
Background• Long-standing Area Wide Optimization Program (AWOP)• Systems out of compliance with Stage 2 applying
optimization concepts (technical tools) to bring them into compliance– Distribution System Optimization Trainings
• Regional group training events– Targeted Technical Assistance (TTA)
• One-on-one system specific assistance• Primary approach for improvements in plants
3
Implementation Approach• Systems selected for TTA based on:
– AWOP Rankings– Enforcement Status
• AWOP tools included in Correction Action Plan– Enforcement Targeting Tool total points – Parent systems with consecutives out of compliance– Direct requests from systems for assistance– Multiple systems in the same geographic area with issues
4
Implementation Approach• TTA selection (continued)
– Optimization concepts have not been implemented• Some systems still pre-chlorinate• Most can remove additional TOC through operational and treatment changes • Many have potential to reduce DBPs through in-plant optimization
• Efforts are made to achieve compliance with “what you already have on hand” when possible.– Avoid major treatment changes– Minimal cost
5
Implementation Approach• Unintended consequences of optimization
– Reduced CT when moving chlorination points
– Bio-growth in sedimentation basins prior to chlorination
– Increased chemical costs– Unhappy chemical sales and
engineering personnel
6
Implementation Approach• Some systems are reluctant to change
– Increased costs due to chemical feeds– A higher need for operator attention, no “set it and forget it”
operation – Concern about “colored water” with permanganates– Worked this way for last 30 years, why should I change?
7
Optimization Tools• Monitoring
– Plant profiles and distribution system monitoring• Monitor at stages through the plant and throughout the distribution system
– TTHM, HAA5, TOC, UV254, chlorine, pH, temperature• Develops a performance baseline to evaluate strategies• Identifies where DBPs are being formed
– Plant vs. distribution system• Serves as a guide on where to concentrate efforts• Conducted multiple times during the year to evaluate operations
8
Optimization Tools• Monitoring (continued)
– Distribution System Influent Hold Studies• Determines DBP formation potential and
chlorine demand• Can be used to evaluate changes in treated water
– Reactive water may suggest inefficient treatment• Used to estimate water age in system
9
Optimization Tools• Monitoring (continued)
– UV254• TOC surrogate/indicator
– Measurement of the amount of light absorbed by organic compounds at 254 nm – Results can be impacted by oxidation and interference (but it’s the best surrogate
we’ve got)– Typically, as UV254 results trends downward, so do DBP levels
• Quick and easy; sample requires basic filtration• Immediate results• Reasonable cost; requires a spec that can adjust to 254 nm wavelength
10
Optimization Tools• Jar Testing
– Evaluate performance of coagulants• Emphasis on UV254/TOC Reduction
– Evaluate performance of pre-oxidation doses– Evaluate performance and application
points of powdered activated carbon– May be used to evaluate pH adjustment as a
last resort; high operator resistance.
11
DBP Optimization Implementation & Activities
12
Getting Started• Prior to site visit
– Determine type of plant• Conventional vs. non-conventional
– Determine raw water source– Review recent monitoring data
• DBPs, turbidity, TOC, calculated CTs– Is DBP plant tap data available?
– Have a discussion with their inspector• Observations and suggestions?
13
Getting Started• Initial Site Visit
– Plant Tour• Determine chemical feed points (what is actually being fed), chemical feed
capabilities (potential), and confirm chemical feed rates and flow rates• Determine raw iron and manganese levels• Observe coagulation process • Discuss with plant personnel what they have “tried” and results
– Conduct initial plant and distribution system monitoring
14
Monitoring• Initial plant profile and distribution system monitoring
– TOC and UV254 after each plant process– DBP samples after each plant process following chlorination– All parameters at the plant tap– DBP samples collected at key locations in the distribution system
• Compliance sites, tank effluent, high residence time, master meters– Shows extent of the problem– Will be repeated to measure improvements
15
MonitoringPlant Profile Manchester Water Works—June 14, 2018
• Chlorine added to the flash mix• Raw water iron=0.239 mg/L; manganese=0.154 mg/L• No permanganate feed
16
HAA THM TOCRaw 0 0 1.8
End Flocculator 23.4 24.2 1.78TOF 35.1 43.6 1.29CFE 45.4 53 1.13Tap 46.7 60 1.15
Consecutive System MM 44.6 62.5 1.18
Monitoring
17
Oxidant Changes• First point of chlorination moved to after settling basin
– Not unusual to see TTHM leaving the plant greater than 80 ppb– If CT allows
• Pre-oxidant determination– Pre-oxidant choice is typically sodium permanganate, especially if
manganese is problematic• Easy to install and implement• Addresses iron and manganese issues
• Pre-oxidant demand determined and met prior to chlorination 18
Oxidant Changes• Permanganate Demand Study
– Goal: Feed sufficient permanganate to address iron and manganese plus a little more to deal with the organics prior to chlorination.
– Procedure to determine demand:• Add 20 liters of raw water to a clean,
white 5-gallon bucket.• Dose bucket with sufficient permanganate
19
Oxidant Changes• Pre-oxidant Demand Study (continued)
– Procedure to determine demand (continued): • Sufficient sodium permanganate dosing:
1. Measure the raw water iron and manganese levels2. Multiply the raw water iron level by 0.84
» 1 mg/L of soluble iron requires 0.84 mg/L of sodium permanganate3. Multiply the raw water manganese level by 1.71
» 1 mg/L of soluble manganese requires 1.71 mg/L of sodium permanganate4. Add values from step 2 and 35. Add 0.5 to address organics
20
Oxidant Changes• Pre-oxidant Demand Study (continued)
– Procedure to determine demand (continued): • After dosing, observe when “pink” goes away.
– If pink goes away in less than 30 minutes, increase permanganate dose. – Get pink to stay for 30 minutes.
• This demand test is done in cases where there is no holding basins or extensive raw water intake line prior to flash mix
• In conventional plants with two stage flocculators, pink should disappear at the beginning of the second flocculator; doing the demand test is still helpful.
21
Oxidant Changes
22
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9
UVA
254
Valu
e
Sample Date
Mountain Water District UVA254 ValuesBefore and After Permanganate
Raw Water End of Train Plant Tap
Began feeding sodium permanganate
TOC Removal• Jar Testing
– Optimize coagulation with the goal of reducing organics• Historically, plant performance has been measured by turbidity removal, not
the removal of organics. – Including a measure for organics removal is key to success.
» UV254
• Start with the system’s product and increase the dose (sometimes double the dose)
– Often, plants are under dosing coagulants by 10 – 30 percent. Under dosing is often seen when plants are using the newer 10% aluminum PACS.
• May try a different product if needed23
Powdered Activated Carbon• There is a significant difference between various carbons with
respect to TOC removal performance. • Must be jar tested and plant trials conducted to find best
performing product and application point• Generally, carbon will improve performance, but may not be
necessary to achieve compliance with DBPs. – Dose and type needed for TOC removal may not be feasible– Operational challenges with PAC might prohibit use
24
Martin County Water District #1 – Case Study • Background
– Referred to Enforcement for DBP MCL violations– Attended a Distribution System Optimization training; however,
plant operations required optimization to achieve compliance.• Feeding low dose 10% aluminum coagulant and polyacrylamide flocculant • Pre-chlorinating with bleach in center well of clarifier• Carbon and sodium permanganate feed capabilities; however, they were not
being utilized. – Very active citizens group that gained the attention of Erin
Brockovich. 25
Martin County Water -Treatment unit #2
Martin County Water District #1 – Case study• Water plant assessment
– Calculated CT for moving the point of chlorination– Conducted a plant profile to evaluate DBP formation– Tested iron and manganese in the raw water for pre-oxidant needs– Jar tested for coagulant feed rates
27
Martin County Water District #1 – Case study• Implementation
– Increased coagulant feed from 18 to 36 ppm– Built a homemade chlorination ring from PEX pipe to apply chlorine
in weirs at top of Hydro-treater – Started sodium permanganate feed– Started copper sulfate feed to control algae
28
Martin County Water District #1 Case Study
29
0
0.02
0.04
0.06
0.08
0.1
0.12
1Q16 2Q16 3Q16 4Q16 1Q17 2Q17 3Q17 4Q17 1Q18 2Q18 3Q18 4Q18 1Q19
TTH
M m
g/l
Monitoring Period
Martin County Water District #1TTHM LRRA
SM7 SM8 Limit
Martin County Water District #1- Case Study
30
0
0.01
0.02
0.03
0.04
0.05
0.06
0.07
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1Q16 2Q16 3Q16 4Q16 1Q17 2Q17 3Q17 4Q17 1Q18 2Q18 3Q18 4Q18 1Q19
HA
A M
G/L
Monitoring Period
Martin County Water District #1HAA LRRA
SM7 SM8 Limit
Summary• Implementation of optimization strategies for DBP control
focuses on using what systems already have with minimal cost • Often a combination of TOC removal and optimizing oxidation
practices is needed to achieve the desired results• The technical assistance efforts can be pretty hands-on, but the
payoff is generally sustained improvements in water quality
31
Reducing Disinfection Byproducts through
Optimization Webinar #2: Approaches to Prioritize Plant Optimization Efforts
April 22, 2019
Webinar #2: Learning Objectives• Understand overall approach for the webinar series, including a brief
review of information covered in the previous webinar• Understand approaches and tools used to prioritize available plant-
based DBP control strategies• Historical water quality data needed to prioritize strategies (Presentation 2)• Surrogate DBP monitoring tool to enhance DBP optimization efforts
(Presentation 3)• Studies that can help assess potential for, and impact of, implementing DBP
control strategies in a treatment plant (Presentation 4)
Question and Answer Session
Matthew Alexander, EPA OGWDW, TSC, [email protected], 513-569-7380Alison Dugan, EPA OGWDW, TSC, [email protected], 513-569-7122
Aaron Hilborn, ADH, [email protected], 501-661-2672Jackie Logsdon, KY DEP, DOW, [email protected], 270-824-7529
David Messer, KY DEP, DOW, [email protected], 606-330-2080