State of Alaska Implementation of MBDP Rules

State of AlaskaImplementation of

MBDP Rules

Carrie BohanEnvironmental Program

SpecialistADEC DW Program

Rule promulgated by US EPA December 16, 1998 Adopted by the State of Alaska on September 28,

2001 Effective for surface water systems or GWUDISW

systems (Subpart H) serving 10,000+ on January 1, 2002

Effective for surface water or GWUDISW systems serving <10,000, and all ground water systems on January 1, 2004

CWS, NTNCWS and TNCWS using chlorine dioxide

Stage 1 D/DBRBasic Requirements

Basic Requirements MCLs and monitoring requirements for TTHMs, HAA5s,

Bromate, and Chlorite

MRDL for Chlorine, Chloramines and Chlorine Dioxide

Treatment technique for enhanced coagulation/softening

to improve precursor removal for conventional filtration

plants

Stage 1 D/DBRBasic Requirements

Monitoring Requirements

Stage 1 D/DBR

Coverage Monitoring Frequency

Compliance

TTHM/HAA5 Surface and GWUDISW serving > 10,000

4/plant/quarter Running Annual Average

Surface and GWUDISW serving 500 – 9,999

1/plant/quarter Running Annual Average

Surface and GWUSIDW serving < 500

1/plant/year in month of warmest water temperature

Running Annual Average

Ground water serving > 10,000 1/plant/quarter Running Annual Average

Ground water serving 10,000 1/plant/year in month of warmest water temperature


Bromate Ozone plants Monthly Running Annual Average

Chlorite Chlorine dioxide plants Daily at EP to DS, Monthly in DS Daily

Chlorine Dioxide

Chlorine dioxide plants Daily at EP to DS Daily

Chlorine/Chloramines

All Systems Same location and frequency as TCR sampling


DBP Precursors

Conventional filtration plants Monthly for TOC and Alkalinity Running Annual Average

Basic Requirements

Compliance Determination If monitoring annually, results of one annual sample

If exceed the MCL, must go to quarterly sampling

If monitoring quarterly, average of past four quarters

(running annual average)

Monthly samples are averaged quarterly, compliance is

based on running annual average of quarterly averages

Stage 1 D/DBRCompliance Determination

Violation Types MCL Violations

TTHMs, HAA5s, Bromate, Chlorite MRDL Violations

Chlorine, Chloramines Treatment Technique Violations

Not meeting Precursor Removal Monitoring and Reporting Violations

Not collecting any individual sample Most commonly distribution system chlorine residual

Not submitting reporting forms in a timely fashion

Public Notification Violations Failure to conduct PN as required for violations

Acute – 24 hours, MCL/TT – 30 days, M/R – 1 year


Reporting Forms www.dec.state.ak.us/eh/dw/publications/forms.html

Quarterly TTHM/HAA5 RAA reports

Quarterly Bromate/Bromide Reports

Quarterly MRDL reports

Quarterly Enhanced Coagulation Reports


Significant Non-Complier List (SNC) Monthly Monitoring (Chlorine residual, MRDL)

A combination of 4 or more MCL or MRDL violations in any 12

consecutive months

A combination of 6 or more MCL, MRDL and Major

Monitoring/Reporting violations in any 12 consecutive months

A combination of 10 or more MCL, MRDL, Major and Minor M/R

violations in any 12 consecutive months


Significant Non-Complier List (SNC) Quarterly Monitoring (TTHM/HAA5s, Bromate)

A combination of 2 or more MCL, MRDL, Treatment Technique,

and Major M/R violations in any 12 consecutive months

A combination of 3 or more MCL, MRDL, Treatment Technique,

and Major or Minor M/R violations in any 12 consecutive months

Annual or Less Frequent Monitoring Failing to collect or report all required samples

If exceed the MCL, go to quarterly monitoring, no violation

Also…. Failure to obtain State approval before making significant

changes to existing treatment process


Significant Non-Complier List (SNC) All SNC violations for Stage 1 take 12 months to Return

to Compliance, or until the end of the quarterly violation Example...


ExampleSystem A

Surface water system serving 425August 2007 Annual samples

TTHM 82 ug/L HAA5 90 ug/L

No ViolationMust begin quarterly samples


TTHM HAA5

Q4 2007

Q1 2008

Q2 2008

Q3 2008

78 ug/L

83 ug/L

67 ug/L 69 ug/L

78 ug/L88 ug/L

101 ug/L

93 ug/L

RAA 79 ug/L 85.3 ug/L

ExampleSystem AQ3 2008

System receives an MCL violation for Q3 2008Must continue quarterly sampling


TTHM HAA5

Q4 2007

Q1 2008

Q2 2008

Q3 2008

78 ug/L

83 ug/L

67 ug/L 69 ug/L

78 ug/L88 ug/L

101 ug/L

93 ug/L




TTHM HAA5

Q1 2008

Q2 2008

Q3 2008

Q4 2008

83 ug/L

67 ug/L

88 ug/L 78 ug/L

86 ug/L72 ug/L

69 ug/L

101 ug/L

RAA 77.5 ug/L 83.5 ug/L

Second consecutive quarterly MCL violation for HAA5s

Qualifies for SNC status


TTHM HAA5

Q4 2008

Q1 2009

Q2 2009

Q3 2009

72 ug/L

64 ug/L

68 ug/L 51 ug/L

43 ug/L62 ug/L

57 ug/L

86 ug/L

RAA 66.5 ug/L 59.3 ug/L

Can take up to 1 year of lower results to bring the RAA below the MCL.

Receives quarterly MCL violations until RAA is below the MCL.

TTHM HAA5

Q1 2008

Q2 2008

Q3 2008

Q4 2008

83 ug/L

67 ug/L

88 ug/L 78 ug/L

86 ug/L72 ug/L

69 ug/L

101 ug/L

RAA 77.5 ug/L 83.5 ug/L


Q3 2009

Example

System A


TTHM HAA5

Q3 2009

Q4 2009

Q1 2010

Q2 2010

62 ug/L

59 ug/L

61 ug/L 51 ug/L

47 ug/L66 ug/L

46 ug/L

43 ug/L


Once RAA is below the MCL, will take one year to come off the SNC List.

TTHM HAA5

Q4 2008

Q1 2009

Q2 2009

Q3 2009

72 ug/L

64 ug/L

68 ug/L 51 ug/L

43 ug/L62 ug/L

57 ug/L

86 ug/L

RAA 66.5 ug/L 59.3 ug/L

Q2 2010

Example

System A


TTHM HAA5

Q3 2009

Q4 2009

Q1 2010

Q2 2010

62 ug/L

59 ug/L

61 ug/L 51 ug/L

47 ug/L66 ug/L

46 ug/L

43 ug/L


In this example, it took 2 years from the initial violation to come off the

SNC List.

TTHM HAA5

Q4 2007

Q1 2008

Q2 2008

Q3 2008

78 ug/L

83 ug/L

67 ug/L 69 ug/L

78 ug/L88 ug/L

101 ug/L

93 ug/L



Rule promulgated January 4, 2006

State has 2 years to adopt January 4, 2008

Have applied for a 2 year extension January 4, 2010

No early implementation by the State

Until Alaska adopts the rule, systems will work directly with EPA


Assuming the State adopts in early 2010 All systems will submit 40/30 certifications, VSS waiver

requests, Standard Monitoring or System Specific Study plans to EPA

Schedule 1 and 2 systems will conduct Standard Monitoring or System Specific Study sampling and submit the IDSE report to EPA

Schedule 3 and 4 systems will submit IDSE report to ADEC

Violations Types Monitoring/Reporting Violations

Failure to submit Monitoring Plan on time

Failure to monitor

MCL violation

LRAA exceeds the MCL

SNC Lists EPA has not yet determined SNC definitions


Promulgated December 16, 1998 and January 14,

2005, respectively Lowered turbidity treatment technique standards

Requires individual filter effluent turbidity monitoring Follow up activities for exceeding certain triggers

Filter Profile, Filter Self Assessment, Comprehensive Performance

Evaluation

Filtered systems must meet 2-log Crypto removal

Increased sanitary survey frequency, no new uncovered

finished water storage tanks

IESWTR/LT1Basic Requirements

Promulgated December 16, 1998 and January 14,

2002, respectively Lowered turbidity treatment technique standards

Requires continuous individual filter effluent turbidity

monitoring Follow up activities for exceeding certain triggers

Filter Profile, Filter Self Assessment, Comprehensive Performance

Evaluation

Filtered systems must meet 2-log Crypto removal

Increased sanitary survey frequency, no new uncovered

finished water storage tanks

IESWTR/LT1Basic Requirements

Types of Violations Monitoring/Reporting

Failure to conduct daily entry point chlorine residual monitoring**

Failure to conduct distribution system chlorine residual monitoring at the same time and location as monthly bacti**

Failure to conduct daily treated water turbidity monitoring** Failure to conduct continuous individual filter effluent

monitoring Failure to conduct triggered activity from IFE readings Failure to submit monthly reports on time Failure to conduct Disinfection Profile & Benchmark if

required Failure to report turbidity MCL violation within 24 hours

IESWTR/LT1Compliance Determination

** SWTR violations

Types of Violations Treatment Technique Violations

Failure to meet 2-log removal of Cryptosporidium

Failure to meet turbidity standards Alternative filtration – 1.49 NTUs 95% of samples

Direct/Conventional filtration – 0.3 NTUs in 95% of samples

MCL Violations Exceeding the turbidity MCL

Alternate filtration – 5 NTUs

Direct/Conventional filtration – 1.49 NTUs

Public Notification Violations Failure to conduct PN as required for violations


Reporting forms http://www.dec.state.ak.us/eh/dw/publications/forms.html

4 Versions Direct/Conventional systems with 3 or more filters

Continuous IFE turbidity monitoring

Direct/Conventional systems with 1 or 2 filters Continuous CFE turbidity monitoring in lieu of continuous IFE

monitoring

Alternative/slow sand systems

Alternative/slow sand systems with reduced monitoring Serve less than 500, reduced to one chlorine residual reading per

day


Significant Non-Complier List (SNC) Unfiltered Systems

Systems that fail avoidance criteria and do not install filtration within 18 months

3 or more Major M/R violations in any 12 consecutive months

5 or more Major and/or Minor M/R violations in any 12 consecutive months

Filtered Systems 4 or more TT violations in any 12 consecutive months 6 or more TT and/or Major M/R violations in any in 12

consecutive months 10 or more TT, Major and/or Minor M/R violations in any 12

consecutive months All SNC violations for SWTRs take 6 months to Return to

Compliance


Promulgated January 5, 2006

State has 2 years to adopt January 5, 2008

Have applied for a 2 year extension January 5, 2010

No early implementation by the State All plan reviews for new systems or system improvements are

held to LT2 standards

Until Alaska adopts the rule, systems will work directly

with EPA

LT2Basic Information

Assuming the State adopts in early 2010 All systems will submit to EPA

Samples schedules for initial source water monitoring Results of initial source water monitoring Notification of uncovered finished water storage tanks

Schedule 1 and 2 systems will submit Bin Classification or mean Crypto sample results to EPA

Schedule 3 system will submit Bin Classification or mean Crypto sample results to ADEC

Schedule 4 systems required to conduct Crypto monitoring will submit sample schedules to ADEC

LT2Rule Adoption

Violations Monitoring/Reporting Violations

Failure to submit monitoring plan Failure to conduct e.coli monitoring Failure to collect a sample within the 5-day period around a

scheduled date (unless extenuating)

LT2Compliance Determination

Violations Treatment Technique Violations

Failure to collect Crypto samples to determine bin classification

Failure to provide required treatment by the established compliance date

Failure to meet monthly Crypto inactivation requirements Ozone or Chlorine dioxide – more than 1 day per month UV – more than 5% of water delivered

Failure to meet IFE performance criteria for tool box credit

SNC List EPA has not yet determined SNC definitions


Reporting Forms New reporting forms are in the works for LT2

Membrane filtration Direct and indirect integrity testing requirements

UV Calculated dose, set point approach

Ozone


EPA’s MDBP Website http://www.epa.gov/safewater/mdbp/mdbp.html Quick Reference Guides and Fact Sheets broken

down by schedule number Source Water Monitoring Guide for LT2 UV and Membranes Guidance Manuals for LT2 IDSE Guidance Manual Simultaneous Compliance Guide for LT2 and

Stage 2 Training on using EPA’s Data Collection and

Tracking System online

More Information

State of Alaska Implementation of MBDP Rules

Documents

major mr violations

minor mr violations

quarterly samplesstage

quarterly violationexample

quarterly samplingif

consecutive monthsstage

consecutive monthsannual

bromatea combination