United States Office of Water EPA 815-R-01-025
Environmental (4607) October 2001
Protection
Agency
SMALL SYSTEM REQUIREMENTS
FOR THE STAGE 1 DISINFECTANTS
AND DISINFECTION BYPRODUCTS
RULE
SMALL ENTITY COMPLIANCE GUIDE
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NOTICE
This guide was prepared pursuant to section 212 of the Small Business Regulatory
Enforcement Fairness Act of 1996 ("SBREFA"), Pub. L. 104-121. THIS DOCUMENT IS
NOT INTENDED, NOR CAN IT BE RELIED UPON, TO CREATE ANY RIGHTS
ENFORCEABLE BY ANY PARTY IN LITIGATION WITH THE UNITED STATES. The
statements in this document are intended solely as guidance to aid you in complying with the
Stage 1 Disinfectants/Disinfection Byproducts (Stage 1 DBF) Rule (63 FR 69390, December
16, 1998). While the guidance contained in this document may assist you, the public, and
State and federal regulators in applying regulatory requirements, the guidance is not a
substitute for those legal requirements; nor is it a regulation itself. Thus it does not impose
any legally-binding requirements on any party, including EPA, States, or the regulated
community. In any civil or administrative action against a small business, small government
or small non-profit organization for a violation of the Stage 1 DBF Rule, the content of this
guide may be considered as evidence of the reasonableness or appropriateness of proposed
fines, penalties or damages. EPA may decide to revise this guide without public notice to
reflect changes in EPA's approach to implementing the Stage 1 DBF Rule or to clarify and
update the text. To determine whether EPA has revised this guide and/or obtain copies,
contact the Safe Drinking Water Hotline at 1-800-426-4791.
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SMALL SYSTEM REQUIREMENTS FOR THE
STAGE 1 DISINFECTANTS AND DISINFECTION
BYPRODUCTS RULE
TABLE OF CONTENTS
Page
Abbreviations used in this document ii
I. Introduction 1-1
II. What Does This Regulation Require? II-l
IE. Step-by-Step Procedures for Compliance With This Rule ni-1
IV. Questions and Answers About the Stage 1 DBPR IV-1
V. The Compliance Assurance Process V-l
APPENDICES
A. Glossary of terms used in this guide A-l
B. Where to obtain more information B-l
C. Questionnaire - How useful was this guide? C-l
D. What to do if you use chlorine dioxide D-l
E. What to do if you use ozone E-l
F. What to do if you are required to do enhanced coagulation or F-l
enhanced softening
G. Stage 1 Disinfectants and Disinfection Byproducts Rule: A Quick G-l
Reference Guide
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Abbreviations used in this document
BAT: Best available technology
CDC: Centers for Disease Control and Prevention
CWS: Community water system
DBF: Disinfection byproducts
DBPP: Disinfection byproduct precursor
DBPR: Disinfectants and Disinfection Byproducts Rule
DOC: Dissolved organic carbon
DWSRF: Drinking Water State Revolving Fund
EPA: United States Environmental Protection Agency
ESWTR: Enhanced Surface Water Treatment Rule
FACA: Federal Advisory Committee Act
FR: Federal Register
GAC10: Granular activated carbon with ten minute empty bed contact time and 180 day
reactivation frequency
HAAS: Haloacetic acids (five)
ICR: Information Collection Rule
IESWTR: Interim Enhanced Surface Water Treatment Rule
MCL: Maximum contaminant level
MCLG: Maximum contaminant level goal
M-DBP: Microbial and Disinfectants/Disinfection Byproducts
mg/L: Milligrams per liter
MRDL: Maximum residual disinfectant level
MRDLG: Maximum residual disinfectant level goal
NTNCWS: Nontransient noncommunity water system
PWS: Public water system
Reg-Neg: Regulatory Negotiation
RUS: Rural Utilities Service
SBREFA: Small Business Regulatory Enforcement Fairness Act
SDWA: Safe Drinking Water Act, or the "Act," as amended in 1986 and 1996
SUVA: Specific ultraviolet absorbance
SWTR: Surface Water Treatment Rule
TOC: Total organic carbon
TTHM: Total trihalomethanes
TNCWS: Transient noncommunity water systems
UV: Ultraviolet light
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I. INTRODUCTION
This document is published by the Environmental Protection Agency (EPA) as our official
compliance guide for small public water systems, as required by the Small Business Regulatory
Enforcement Fairness Act of 1996. Before you begin using the guide, you should know that the
information in this guide was compiled and published on October 31, 2001. EPA is continually
improving and upgrading its rules, policies, compliance programs, and outreach efforts. You can
determine whether EPA has revised or supplemented the information in this guide by calling the
Safe Drinking Water Hotline at 800-426-4791.
A. Who should use this guide?
This guide is intended for use by small public water systems - those serving fewer than 10,000
people. It is specifically intended for small community water systems (CWS) and nontransient
noncommunity water systems (NTNCWS) that add a chemical disinfectant or oxidant, such as
chlorine, chloramines, ozone, or chlorine dioxide, as part of the drinking water treatment process.
Finally, there are a limited number of requirements that apply to transient noncommunity water
systems that add chlorine dioxide as part of their drinking water treatment process.
B. What does the guide cover?
This guide contains a general introduction to the background, development, and benefits of this
rule. Section II contains background information on the development of this rule, along with a
general explanation of the rule's requirements and a brief discussion of other rules that EPA is
developing that will help address pathogen and chemical byproduct risks that are not addressed in
this rule. Section III contains a detailed explanation of the regulatory requirements of the Stage 1
Disinfectants and Disinfection Byproducts Rule (Stage 1 DBPR) for systems serving fewer than
10,000 people, including sections specifically addressing requirements for systems based on
source water type and disinfectant or treatment used. Section IV includes questions and answers
about provisions in the rule. Section V is an overview of EPA's compliance assurance process.
Appendix A contains a glossary of terms used in the rule and in this guide. Appendix B contains
instructions on how to order the technical guidance manuals and other publications that EPA has
developed to support implementation of and compliance with this rule. Appendix C is a
questionnaire on how to make future versions of this guide more useful. Appendices D, E, and F
contained detailed explanations of requirements for technologies that few small systems use
(chlorine dioxide, ozone, and conventional filtration treatment, respectively), but are required to
comply with if used.
C. How do I use the Guide?
We suggest that you read through the entire guide. Refer to Appendix A if you find a term that
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you are not familiar with. After looking at the entire guide, go back to Section III to begin to
identify specific requirements that apply to your system.
D. How do I obtain a complete copy of the rule?
The Stage 1 Disinfectants/Disinfection Byproducts Rule was published in the Federal Register on
December 16, 1998 (63 FR 69390). You may call the Safe Drinking Water Hotline at 800-426-
4791 to request a copy. You may also download an electronic copy from the following internet
address; http://www.epa.gov/safewater/mdbp/dbpfr.html. Appendix B has further information on
ordering the guidance manuals that support this rule or downloading them from the Internet. The
Code of Federal Regulation will also provide needed information, refer to the following sections
in 40 CFR Ch. 1 displayed in exhibit 1-1.
Exhibit 1-1 Stage 1 DBPR Regulatory Requirements
Title
Maximum contaminant level goals for
disinfection byproducts.
Maximum residual disinfectant level goals for
disinfectants.
Maximum contaminant levels for disinfection
byproducts.
Maximum residual disinfectant levels.
General requirements.
Analytical requirements.
Compliance requirements.
Reporting and recordkeeping requirements.
Treatment technique for control of
disinfection byproduct (DBF) precursors.
CFR Section number
141.53
141.54
141.64
141.65
141.130
141.131
141.132
141.134
141.135
The Code of Federal Regulation can be accessed on the internet at
http://www.gpo.gov/nara/cfr/index.html.
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II WHAT DOES THIS REGULATION REQUIRE?
A. What human health issues does this rule address and why is it important?
In 1990, EPA's Science Advisory Board, an independent panel of experts established by
Congress, cited drinking water contamination as one of the most important environmental risks
and indicated that disease-causing microbial contaminants (i.e., bacteria, protozoa, and viruses) -
also known as pathogens - are probably the greatest remaining health-risk management
challenge for drinking water suppliers. Data from the Centers for Disease Control (CDC) confirm
this concern and indicate that between 1980 and 1994, 379 waterborne disease outbreaks were
reported, with over 500,000 cases of disease. During this period, a number of agents were
implicated as the cause, including protozoa, viruses, bacteria, and several chemicals. Most of the
cases (but not most of the outbreaks) were associated with surface water, including a 1993
outbreak of 400,000 cases of cryptosporidiosis (caused by the protozoan Cryptosporidium) in
Milwaukee.
One of the key regulations EPA has developed to date to counter pathogens in drinking water is
the 1989 Surface Water Treatment Rule (SWTR). Among its provisions, the rule requires that a
surface water system have sufficient treatment to reduce the source water concentration of
Giardia lamblia and viruses by at least 99.9 percent (3 log) and 99.99 percent (4 log),
respectively. The goal of the SWTR is to reduce risk to less than one infection per year per
10,000 people. However, the SWTR's limitations include: 1) some systems have high pathogen
concentrations that, when reduced by the levels required under the rule, still may not meet this
health goal, and 2) the rule does not specifically control for the protozoan Cryptosporidium.
In addition to these microbial issues, there is another potentially complicating public health
concern. Many water systems treat their water with a chemical disinfectant in order to inactivate
pathogens. The public health benefits of common disinfection practices are significant and well-
recognized; however, disinfection poses risks of its own. While disinfectants are effective in
controlling many harmful microorganisms, they react with organic and inorganic matter (known
as disinfection byproduct precursors—DBPPs) in the water and form DBFs, some of which pose
health risks at certain levels. Since the discovery of chlorination byproducts in drinking water in
1974, many toxicological studies have shown some DBFs to be carcinogenic (cancer-causing)
and/or to cause reproductive or developmental effects in laboratory animals. Additionally,
exposure to high levels of disinfectants over long periods of time may cause health problems,
including damage to blood and kidneys. While many of these studies have been conducted at
high doses, the weight-of-evidence indicates that disinfectants and DBFs present a potential
public health problem that must be addressed. One of the most complex questions facing water
supply professionals is how to reduce risks from disinfectants and DBFs while providing
increased protection against microbial contaminants. Much of the population is exposed to these
risks; therefore, a substantial concern exists.
Health risks associated with some DBFs are currently addressed by the regulation of total
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trihalomethanes (TTHM) at public water systems (PWSs) serving 10,000 or more people. EPA,
however, believes that the Stage 1 DBPR will significantly decrease the risks posed by DBFs and
disinfectants. The Stage 1 DBPR will broaden public health protection by 1) reducing the TTHM
allowable level, 2) regulating disinfectants and additional DBFs, 3) reducing risks from
unregulated DBFs, and 4) extending coverage to all systems, including small PWSs not currently
regulated for TTHM or other DBFs.
The new rules are a product of six years of collaboration among water suppliers; environmental,
consumer, and public health groups; local elected officials; and local, State, and Federal
regulatory and public health agencies. To address the complex issues associated with regulating
pathogens, EPA first launched a rule-making process in 1992 and convened a Regulatory
Negotiation (RegNeg) Advisory Committee under the Federal Advisory Committees Act
(FACA), representing a range of stakeholders affected by possible regulation. The RegNeg
Committee met over a period of 10 months and arrived at a consensus proposal for taking
incremental steps toward addressing both DBFs and microbial pathogens. The 1992 consensus-
building process resulted in the three following regulatory proposals—
- A staged approach to regulation of DBFs (referred to as the Stage 1 and Stage 2 DBPRs)
incorporating maximum contaminant levels (MCLs), maximum residual disinfectant
levels (MRDLs), and treatment technique requirements;
- A companion Enhanced Surface Water Treatment Rule (ESWTR), to be finalized at
different times for large (those serving at least 10,000 people) and small systems,
designed to improve control of pathogens and prevent inadvertent reductions in microbial
safety as a result of DBF control efforts; and,
- An Information Collection Rule (ICR) to collect information necessary to reduce many
key uncertainties (about issues such as health effects and formation and occurrence of
DBFs) prior to subsequent negotiations for the Stage 2 DBPR.
Congress amended the Safe Drinking Water Act (SDWA) in 1996 and affirmed the strategy
developed by the RegNeg Committee. Congress also established a series of new statutory
deadlines for the rules.
In 1997, a similar FACA process was implemented with the Microbial-Disinfectants/Disinfection
Byproducts (M-DBP) Advisory Committee. The M-DBP Committee convened to collect, share,
and analyze new information available since the rules were proposed in 1994 and review
previous assumptions made during the RegNeg process, as well as build consensus on the
regulatory implications of this new information. The Stage 1 DBPR and the IESWTR are the
result of the FACA process.
B. Summary of the new regulation
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This section contains a summary of the major requirements of this rule, but does not include
specific monitoring requirements or how to calculate compliance. Compliance for some
regulated compounds is based on a running annual average, while compliance for others is based
on shorter periods. See Section III for details.
MCLGs andMCLsfor disinfection byproducts
The Stage 1 DBPR sets maximum contaminant level goals (MCLGs) for some of the regulated
DBFs, a more stringent maximum contaminant level (MCL) for total trihalomethanes (TTHM),
and new MCLs for haloacetic acids (five) (HAAS), bromate, and chlorite. MCLGs are set at
concentrations at which no known or anticipated adverse health effects are expected to occur,
with an adequate margin of safety. They are non-enforceable public health goals. MCLs are
enforceable contaminant standards set as close as is feasible to MCLGs. These MCLs, along
with the maximum residual disinfectant levels (MRDLs) and the treatment technique explained
in the following paragraphs, will help reduce exposure to DBFs and disinfectants and their
associated health effects. Exhibit II-l displays disinfection byproducts with their MCLG and
MCL.
Exhibit II-l MCLGs and MCLs for Disinfection Byproducts
Disinfection Byproduct
Total Trihalomethanes
(TTHM), consisting of:
Chloroform
Bromodichloromethane
Bromoform
Dibromochloromethane
Five Haloacetic Acids (HAAS),
consisting of:
Monochloroacetic Acid
Dichloroacetic Acid
Trichloroacetic Acid
Monobromoacetic Acid
Dibromoacetic Acid
Chlorite
Bromate
MCLG (mg/L)
ND
ND
0
0
0.06
ND
ND
0
0.3
ND
ND
0.8
0
MCL (mg/L)
0.080
ND
ND
ND
ND
0.060
ND
ND
ND
ND
ND
1.0
0.010
ND - not determined
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MRDLGs andMRDLsfor disinfectant residuals
To protect against potential health risks caused by high levels of residual disinfectants, the Stage
1 DBPR sets the following maximum residual disinfectant level goals (MRDLGs) and maximum
residual disinfectant levels (MRDLs). Like MCLGs and MCLs, respectively, MRDLGs are non-
enforceable, while MRDLs are enforceable and are set as close as is feasible to MRDLGs. In
exhibit II-2 the MRDLG and MRDL are displayed for chlorine, chloramies, and chlorine dioxide.
Exhibit II-2 MRDLG and MRDL for Disinfectants
Disinfectant
Chlorine
Chloramines
Chlorine Dioxide
MRDLG (mg/L)
4
4
0.8
MRDL (mg/L)
4.0
4.0
0.8
Treatment technique for disinfection byproduct precursors
The rule includes an enforceable treatment technique that applies to subpart H systems (systems
that use surface water or ground water under the direct influence of surface water—GWUDI—as
a source) using conventional filtration treatment. There are very few small systems that will have
to meet this requirement, since it does not apply if you use only ground water or if you treat
surface water using a filtration technology other than conventional filtration treatment. The
treatment technique was established because disinfectants can react with organic and inorganic
disinfection byproduct precursors (DBPPs) to form both regulated and non-regulated DBFs. The
treatment technique applies to subpart H systems with conventional filtration treatment because
the Advisory Committee determined that such systems generally had higher levels of disinfection
byproduct precursors and conventional filtration treatment was able to lower those levels (and
consequently DBF levels) economically. The treatment technique requirements in the rule are
designed to provide public health protection by reducing the production of both regulated and
unregulated DBFs. Compliance with the treatment technique can be achieved by removing
specified percentages of total organic carbon (TOC) using enhanced coagulation or enhanced
softening. Alternatively, systems may comply by showing they meet alternative compliance
criteria that indicate additional removal of DBPPs by that particular system is unnecessary or
impractical. For example, there is an alternative compliance criterion for systems which have a
low level of TOC in their source or treated water. The treatment technique and these alternatives
are discussed in Appendix F.
Best available technology (BAT)
EPA has specified the Best Available Technology (BAT) for each MCL and MRDL established
in the rule. These technologies and methods are believed to be effective in controlling chemicals
in drinking water while remaining economically feasible for PWSs to employ. PWSs must use
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the specified BAT if they wish to qualify for variances. Otherwise, systems are not required to
install BAT and may use any technology to achieve compliance. The BAT for DBFs and
disinfectants are shown in exhibit II-4.
Exhibit II-3 Best Available Technology for DBFs and Disinfectatns
Chemical
DBFs
Disinfectants
TTHM and HAAS
Chlorite
Bromate
Chlorine, chloramine,
and chlorine dioxide
Best Available Technology
Enhanced coagulation or granular activated carbon (GAC 10), with
chlorine as the primary and residual disinfectant
Control of treatment processes to reduce disinfectant demand and control
of disinfection treatment processes to reduce disinfectant levels
Control of ozone treatment process to reduce production of bromate
Control of treatment processes to reduce disinfectant demand and control
of disinfection treatment processes to reduce disinfectant levels
Public water system recordkeeping and reporting requirements
For each disinfectant, contaminant, contaminant group, and treatment technique, EPA has
developed routine compliance monitoring schemes to be protective of acute and chronic health
concerns. The compliance monitoring requirements vary by the size and type of system, the
treatment employed, and the disinfectant used. In many cases, systems may reduce monitoring to
a frequency and location that will provide a worst-case sample after establishing a baseline that
demonstrates that violations are unlikely.
Systems required to sample quarterly or more frequently must report to the State within 10 days
after the end of each quarter in which the samples were collected. Those required to sample less
frequently than quarterly must report to the State within 10 days after the end of each monitoring
period in which samples were collected. Systems that are required to conduct additional
monitoring because of the disinfectant used (e.g., chlorine dioxide) are subject to additional
reporting requirements if certain concentrations are exceeded. Specifics concerning monitoring
and reporting are in Section III and Appendices D, E, and F.
Laboratory methods and certification
The rule specifies analytical methods for measuring each relevant water quality parameter,
disinfectant, contaminant, and DBPP. Consistent with current regulations, only certified
laboratories can analyze samples for compliance with the MCLs. For disinfectants and other
specified parameters that EPA believes can be adequately measured by other than certified
laboratories, and for which there is good reason to allow on-site analysis (e.g., for samples that
may deteriorate before reaching a certified laboratory), EPA requires that analyses be conducted
by a party approved by the State.
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Benefits of the Rule
The Stage 1 DBPR is expected to reduce the risks associated with exposure to disinfectants and
DBFs. The MCLs will reduce exposure to specific DBFs from the use of ozone (byproduct:
bromate), chlorine dioxide (byproduct: chlorite), and chlorine (byproducts: TTHM and five
haloacetic acids - HAAS). In addition, the implementation of a treatment technique (enhanced
coagulation/ enhanced softening) will reduce overall exposure to the broad range of non-
specified DBFs. In the Regulatory Impact Analysis for the Stage 1 DBPR, EPA estimated that the
rule will result in a national annual average reduction in TTHM levels of 24 percent. As many as
140 million people will have increased protection from DPBs and their potential health risks,
including bladder cancer and adverse developmental and reproductive health effects.
C. Compliance timetable
The 1979 Total Trihalomethane (TTHM) Rule requirements apply only to systems serving
10,000 or more people. The Stage 1 Disinfectants and Disinfection Byproducts Rule (DBPR)
covers a larger number of PWSs, applying to all community water systems (CWSs) and
nontransient noncommunity water systems (NTNCWSs) that add a chemical disinfectant for
either primary or residual treatment or as an oxidant. In addition, certain requirements apply to
transient noncommunity water systems (TNCWSs) that use chlorine dioxide.
Subpart H systems (systems that use surface water or ground water under the direct influence of
surface water—GWUDI—as a source) serving 10,000 or more people must comply with the
requirements of the Stage 1 DBPR no later than January 1, 2002. Subpart H systems that serve
fewer than 10,000 people, and all affected ground water systems, must comply with the
requirements no later than January 1, 2004. The timetable for the Stage 1 DBPR is presented in
Table 1.
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Exhibit II-4 Timetable for the Stage 1 DBPR Requirements for Systems serving
fewer than 10,000 People
Date
December 16, 1998
February 16, 1999
January 2003
January 1, 2004
June 30, 2005
Rule Requirement1
Rule published in Federal Register.
Methods specified in §141.131 for analyzing disinfection byproducts, disinfection
residuals, and DBF precursors effective.
Subpart H systems using conventional filtration treatment may begin optional
monitoring to determine Step 1 TOC removals before the compliance date.
- Requirements effective for systems serving fewer than 10,000 people.
- Monitoring requirements
- Reporting and recordkeeping requirements
- Compliance
- MCLs for TTHM, HAAS, bromate2, and chlorite3
- MRDLs for chlorine, chloramines, and chlorine dioxide3
- Treatment technique for control of DBF precursors4
- Subpart H and ground water TNCWSs that use chlorine dioxide must comply with
requirements for chlorine dioxide.
Systems that made a clear and irrevocable financial commitment before the applicable
compliance date to install technologies that limit TTHM and HAAS to 0.040 mg/L and
0.030 mg/L, respectively, must have these technologies installed and operating.
NOTES:
1. Compliance monitoring must begin when noted. The first compliance calculations are made based on whether
compliance is monthly or more frequently (such as chlorine dioxide and chlorite) or as a running annual average
(such as TTHM and bromate). Systems are not required to use data collected prior to the date noted in this table for
compliance determinations.
2. Only for systems that use ozone
3. Only for systems that use chlorine dioxide
4. Only for subpart H systems that use conventional filtration treatment
D. How does this rule relate to other federal, State, and local requirements?
The Stage 1 DBPR and the IESWTR were published simultaneously to address the inherent
tradeoffs between protection from microbial contamination and the potential health effects from
disinfectants and their byproducts. These rules are the first in a series of rules that will continue
to address the public health concerns associated with microbial pathogens and chemical
disinfectants Of course, you are still required to continue to meet all existing requirements.
There are other rules being developed that may apply to your system. The future regulations
intended for the control of pathogens and DBFs are listed below. You may call the Safe
Drinking Water Hotline at 1-800-426-4791 for more information on or the current status of these
rules or other drinking water rules.
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Long Term 1 Enhanced Surface Water Treatment Rule
While the Stage 1 DBPR applies to systems of all sizes, the IESWTR generally applies only to
subpart H systems serving at least 10,000 people. The exception is that the State is required to
conduct a sanitary survey at your system every three to five years. The LT1ESWTR will
strengthen microbial protection for subpart H systems serving fewer than 10,000, while also
addressing the risk tradeoff issue as small systems implement the Stage 1 DBPR. This rule will
generally track the approaches in the IESWTR for improved turbidity control (including
individual filter monitoring) and disinfection benchmarking and profiling.
Filter Backwash Recycling Rule
EPA is also required to develop standards for recycling of filter backwash. The Agency
published the final rule on June 8, 2001 (66 FR 31086).
Long Term 2 Enhanced Surface Water Treatment/Stage 2 Disinfection Byproducts Rules
In the 1996 Amendments to the Safe Drinking Water Act, EPA is required to finalize the Stage 2
DBPR to further address risks from disinfection byproducts, based on new health effects
research, occurrence data, and treatment information. EPA plans to also develop a Long Term 2
ESWTR to ensure that microbial protection is not compromised and may include site-specific
treatment requirements if data are available to make decisions. EPA began discussions with
stakeholders on the development of these rules in December 1998 and set up an advisory
committee in March 1999 and is currently developing rule proposals for public comment.
Ground Water Rule
EPA is also developing a rule to ensure microbial protection for ground water systems through
the use of disinfection and other barriers to fecal contamination.
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Ill STEP-BY-STEP PROCEDURES FOR
COMPLIANCE WITH THIS RULE
A. How can I tell if I am subject to this rule?
The Stage 1 DBPR applies to all community water systems and nontransient noncommunity
water systems that add a chemical disinfectant, as well as transient noncommunity water systems
that use chlorine dioxide (since chlorine dioxide has short-term health effects that may occur
based on limited exposure). However, systems will monitor at various frequencies depending on
source water type (subpart H and ground water) and size. Additionally, chemicals monitored may
also vary depending on system type and the primary disinfectant used. For this reason, tables that
outline the monitoring and reporting requirements are presented for each system size and type.
If you do not know what type of water system you operate, contact your State Drinking Water
regulatory agency. If you do not know who your State agency is, call the Safe Drinking Water
Hotline at 800-426-4791.
B. What requirements am I subject to?
This section includes the federal requirements that you must comply with. The requirements for
monitoring and compliance are found in section HID., while those for recordkeeping are found
in section III.E. and those for reporting are found in III.F.
Your State may impose different requirements, as long as those requirements are at least as
stringent as the federal requirements. Your State may also impose more requirements than the
federal requirements, such as additional monitoring or compliance with stricter standards.
III-l
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Exhibit III-l Stage 1 DBPR Requirements
You must conduct the monitoring, compliance determinations, reporting , and recordkeeping
specified in this section. In addition, you are required to conduct additional monitoring,
compliance determinations, reporting and recordkeeping if:
1. You use chlorine dioxide in treating your water. This includes any use of chlorine
dioxide, not just chlorine dioxide used for meeting disinfection requirements. Additional
requirements are found in Appendix D.
2. You use ozone in treating your water. This includes any use of ozone, not just ozone
used for meeting disinfection requirements. Additional requirements are found in
Appendix E.
3. You are a subpart H system (you treat either surface water or ground water under the
direct influence of surface water) and you use conventional filtration treatment (consisting
of coagulation, flocculation, sedimentation, and filtration) in treating your water.
Additional requirements are found in Appendix F.
In addition, you must develop and implement a monitoring plan that specifies 1) location and
schedules for collecting all required samples, 2) procedures for calculating compliance with
MCLs, MRDLs, and treatment techniques, and 3) if receiving water as a consecutive system, or
supplying water to a consecutive system, how the entire distribution system is represented by the
monitoring plan. If you are a subpart H system serving more than 3,300 people, you must submit
your monitoring plan to the State with your first monitoring report. If you are a ground water
system or a subpart H system serving 3,300 or fewer people, you are just required to keep your
monitoring plan on file.
Finally, your system must be operated by a qualified operator. Your State will set criteria for
qualification; EPA expects that many States will have different levels of qualification, based on
type of source water, type of treatment, and population served. You should contact the State to
get further information.
C. When do I need to comply?
You must begin to comply with the requirements in the rule as of January 1, 2004. For those
chemicals that you must monitor for monthly or more frequently (such as chlorine), you must
take your first samples in January 2004. For those chemicals that you must monitor for quarterly
(such as TTHM for some systems), you must take your first samples in the January-March 2004
quarter. For those chemicals that you must monitor for annually (such as TTHM for some
systems), you must take your first samples in the month of warmest water temperature in 2004
(generally in the July-September quarter, since that is probably the period of warmest water
temperature). You need to develop and follow a monitoring plan that indicates the location and
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timing of all monitoring required by this rule by the time you take your first compliance sample.
There are no requirements for you to conduct any monitoring prior to 2004 under the Stage 1
DBPR, and failure to conduct monitoring prior to 2004 is not a violation. However, EPA
believes that you should conduct monitoring on your own to see whether you need to modify
your treatment practices to meet the requirements of this rule prior to the compliance date. This
will allow you to fully consider many low-technology, lower-cost alternatives and to conduct
necessary bench- or pilot-scale testing to improve performance without going into violation.
D. What, when, and how must I monitor or test?
There are three categories of small systems that have monitoring requirements under this rule.
They are:
- Subpart H systems that serve 500 to 9,999 people.
- Subpart H systems that serve fewer than 500 people.
- Ground water systems that serve fewer than 10,000 people.
Note: A subpart H system is a system using surface water or ground water under the direct
influence of surface water as a source
If you do not know what type of system you are, you should contact your State agency to confirm
this information.
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Exhibit III-2 General Monitoring Requirements for the Stage 1 DBPR
Monitored
Parameters
TTHM
HAAS
Chlorine
Chloramines
Chlorine dioxide
Bromate
Chlorite
DBPP precursor
removal (enhanced
coagulation/enhanced
softening
System Type
Subpart H 500-
9,999 people
yes
yes
only if chlorine is used
as residual disinfectant
only if chloramines are
used as residual
disinfectant
only if chlorine dioxide
is used
only if ozone is used
only if chlorine dioxide
is used
only if conventional
filtration treatment1 is
used
Subpart H
<500people
yes
yes
only if chlorine is used
as residual disinfectant
only if chloramines are
used as residual
disinfectant
only if chlorine dioxide
is used
only if ozone is used
only if chlorine dioxide
is used
only if conventional
filtration treatment1 is
used
Ground water
<10,000 people
yes
yes
only if chlorine is used
as residual disinfectant
only if chloramines are
used as residual
disinfectant
only if chlorine dioxide
is used
only if ozone is used
only if chlorine dioxide
is used
No
NOTES:
1. "Conventional filtration treatment" consists of coagulation, flocculation, sedimentation, and filtration.
Exhibit III-l displays the general monitoring requirements for Stage 1 DBPR for each of the
groups that require monitoring, these groups have different monitoring requirements. Monitoring
for TTHM and HAAS is based on the number of treatment plants that you operate. Generally,
this is equal to the number of entry points into the distribution system. However, the State can
consider multiple entry points from the same aquifer as a single treatment plant for monitoring
purposes. Contact the State if you think this may apply to you.
You may also elect to do optional monitoring in order to qualify for reduced monitoring for
certain parameters. You are not required to conduct this monitoring and conducting this
monitoring does not guarantee that you will qualify for reduced monitoring. Since not all
systems are required to do the basic monitoring, make sure that you are required to do the basic
monitoring before you decide to do the optional monitoring. Exhibit III-2 illiterates the optional
monitoring for Stage 1 DBPR.
III-4
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Exhibit III-3 Optional Monitoring for the Stage 1 DBPR
Optional
Parameter
Bromide
TOC
Ultraviolet
(UV)
absorbance
Dissolved
organic
carbon (DOC)
Purpose of Monitoring
Qualify for reduced bromate
monitoring
Qualify for reduced TTHM and
HAAS monitoring
Qualify for one of the alternative
compliance criteria for DBF
precursor removal compliance 2
Qualify for one of the alternative
compliance criteria for DBF
precursor removal compliance 2
Type of System
Any system that uses ozone
Any subpart H system that does not
use conventional filtration treatment l
Any subpart H system that uses
conventional filtration treatment
Any subpart H system that uses
conventional filtration treatment
NOTES:
1. Subpart H systems that use conventional filtration treatment are required to conduct TOC monitoring
under the DBF precursor removal (enhanced coagulation/enhanced softening) requirements. Other
subpart H systems can use the data to qualify for reduced monitoring.
2. UV absorbance and DOC monitoring are used to determine whether a system can meet the alternative
compliance criteria for either source water specific UV absorbance (SUVA) or treated water SUVA.
m-5
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Exhibit III-4 What ROUTINE TTHM, HAAS, CHLORINE, AND CHLORAMINE MONITORING
must I conduct under the Stage 1 DBPR?
Chemical
TTHM and
HAAS
Chlorine and
Chloramines3
Routine Frequency
Where monitoring must be conducted
Subpart H system serving 500-9, 999 people
1 sample per plant per quarter
Location representing maximum residence time1.
Subpart H system serving fewer than 5 00 people
1 sample per plant per year, during the
month of warmest water temperature 2
Location representing maximum residence time1.
Ground water system serving fewer than 1 0, 000 people
1 sample per plant per year, during the
month of warmest water temperature 2
Location representing maximum residence time1.
All systems serving fewer than 1 0, 000 people
Same time as total conform samples are
taken
Same points as total coliform samples are taken.
NOTES:
1. If you decide to sample more frequently than the minimum required, at least 25% of all samples collected each
quarter (including those taken in excess of the required frequency) must be taken at locations that represent the
maximum residence time of the water in the distribution system. The remaining samples must be taken at locations
representative of at least average residence time in the entire distribution system (account for number of people
served, different sources of water, different treatment methods)
2. If your one sample per year exceeds either 0.080 mg/L for TTHM or 0.060 mg/L for HAAS, you are not
immediately in violation. You must begin to take samples at this same location every quarter. Once you have four
quarterly samples, you will make your first compliance determination.
3. If you are a subpart H system, you may use the results of residual disinfectant concentration sampling conducted
under §141.74(b)(6)(i) for systems that do not filter or §141.74(c)(3)(i) for systems that filter, in lieu of taking
separate samples.
m-6
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Exhibit III-5 What REDUCED MONITORING FOR TTHM, HAAS, CHLORINE, AND CHLORAMINES may I
conduct under the Stage 1DBPR?
Chemical
TTHM and
HAAS
Chlorine and
Chloramines
Reduced
Frequency
Where monitoring
must be conducted
Conditions to qualify for reduced
monitoring
Subpart H system serving 500-9,999 people
1 sample per plant per
year during month of
warmest temperature '
In the distribution
system at a location
representing maximum
residence time.
- Annual average source water TOC • 4.0
mg/L and
- Annual average TTHM • 0.040 mg/L
and
- Annual average HAAS • 0.030 mg/L
Subpart H system serving fewer than S 00 people
You may NOT reduce your monitoring to less than the routine frequency of one time per year
per plant.
Ground water system serving fewer than 10,000 people
1 sample per plant per
three year cycle during
month of warmest
temperature 2
In the distribution
system at a location
representing maximum
residence time.
- Annual average TTHM • 0.040 mg/L
and annual average HAAS • 0.030 mg/L
for two consecutive years
OR
- Annual average TTHM • 0.020 mg/L
and annual average HAAS • 0.015 mg/L
for one year
All systems
You may NOT reduce monitoring for disinfectant residuals.
NOTES:
1. You may remain on reduced monitoring frequency as long as your TTHM concentration does not exceed 0.060
mg/L, your HAAS concentration does not exceed 0.045 mg/L, and your annual average source water TOC level
does not exceed 4.0 mg/L. If you exceed any of these concentrations, you must revert to routine monitoring.
2. You may remain on reduced monitoring frequency as long as your TTHM concentration does not exceed 0.060
mg/L and your HAAS concentration does not exceed 0.045 mg/L. If you exceed either the TTHM or HAAS
concentrations, you must revert to routine monitoring if you do not exceed 0.080 mg/L for TTHM and 0.060 mg/L
for HAAS. You must go to increased (quarterly) monitoring if you exceed either 0.080 mg/L for TTHM or 0.060
mg/L for HA AS.
m-7
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Exhibit III-6 How do I DETERMINE IF MY SYSTEM IS IN COMPLIANCE with the TTHM
and HAAS MCLs and MRDLs in the Stage 1 DBPR?
Chemical
TTHM and
HAAS
Chlorine and
Chloramines
Compliance is based on...
If you monitor each plant at least once per quarter
Running annual arithmetic average, computed quarterly, of quarterly arithmetic
averages of all samples collected (routine monitoring).
- If annual arithmetic average of quarterly averages covering any consecutive 4-quarter period
exceeds the MCL, then you are in violation.
- You must notify the public and report to the State if in violation.
If you monitor each plant no more than once per year
Annual arithmetic average of all samples collected (routine and reduced monitoring).
- If annual sample (or average of annual samples, if you have more than one plant) exceeds the
MCL, then you must begin quarterly monitoring at each plant.
- If an annual average exceeds the MCL and you are on reduced monitoring, you must revert
to routine monitoring immediately.
All systems
Running annual arithmetic average, computed quarterly, of quarterly averages of all
samples collected.
- If annual arithmetic average of quarterly averages covering any consecutive 4-quarter period
exceeds the MRDL, then you are in violation.
- You must notify the public and report to the State if in violation.
- If you switch between chlorine and chloramines for residual disinfection during the year,
compliance must be determined by including together all monitoring results of both chlorine
and chloramines.
NOTES:
1. Where compliance is based on a running annual average of monthly or quarterly samples or averages and your
failure to monitor makes it impossible to determine compliance with the MCLs or MRDLs, this failure to monitor
will be treated as a violation for the entire period covered by the annual average.
2. All samples taken and analyzed under the provisions of the monitoring plan must be included in determining
compliance, even if that number is greater than the minimum required.
3. If during the first year of monitoring, any individual quarter's average will cause the running annual average of
that system to exceed the MCL, you are out of compliance at the end of that quarter.
E.
What records do I need to keep and for how long?
You must keep records of chemical monitoring and compliance determination for 10 years. You
must keep your monitoring plan as long as it is current. You must also keep superceded
monitoring plans for as long as you are required to keep monitoring results collected under those
monitoring plans.
III-8
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F.
What, when, and to whom must I report?
Exhibit III-7 What must be reported
Chemical
TTHM and
HAAS
Chlorine and
Chloramines
What must be reported 1'2'3
I/you
monitor each plant at least once per quarter
- Number of samples taken during last quarter (routine monitoring)
- Location, date, result of each sample taken during last quarter
- Arithmetic average of all samples taken in last quarter
- Annual arithmetic average of quarterly averages for last 4 quarters
- Whether MCL was violated
If you monitor each plant no more thai once per year
- Number of samples taken during last quarter (routine monitoring)
- Location, date, result of each sample taken during last quarter
- Arithmetic average of all samples taken in last quarter
- Annual arithmetic average of quarterly averages for last 4 quarters
- Whether MCL was violated
All systems
- Number of samples taken during each month of last quarter
- Monthly arithmetic average of all samples taken in each month
- Arithmetic average of all monthly averages for last 12 months
- Whether MRDL was violated
NOTES:
1. If you are required to sample quarterly or more frequently, you must report to the State within 10 days
after the end of each quarter in which samples were collected.
2. If you are required to sample less frequently than quarterly, you must report to the State within 10
days after the end of each monitoring period in which samples were collected.
3. The State may choose to perform calculations and determine whether the MCL, MRDL, or treatment
technique was met in lieu of having you report that information.
G.
What do I have to do if I use chlorine dioxide, ozone, or conventional
filtration treatment?
If you use chlorine dioxide, ozone, or conventional filtration treatment, you have additional
requirements under this rule. The additional requirements if you use chlorine dioxide are in
Appendix D. The additional requirements if you use ozone are in Appendix E. The additional
requirements if you use conventional filtration treatment are in Appendix F.
III-9
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H. How do I minimize harm if I think I am out of compliance?
If you are out of compliance, you are required to contact your State agency within 48 hours of the
failure to comply. When you contact the State, explain the situation fully and ask for
recommendations on what to do. There are many actions that you might take that will cause the
problem to get worse. For example, if you stop adding a disinfectant if you have a TTHM
violation, you risk compromising the protection from disease-causing microorganisms. If you
stop water from entering the distribution system, you risk losing pressure in the distribution
system needed for fire fighting and to prevent infiltration. Therefore, it is important to work with
the State to address your unique circumstances.
I. Where do I go for help?
There are many sources of information available to help you meet the requirements in this rule.
You can review EPA's guidance manuals (see Appendix B on how to order these manuals). You
can contact your State drinking water agency. You can contact your State or regional chapters of
such organizations such as the National Rural Water Association and the American Water Works
Association. You can contact a larger water supplier in your area who might be willing to help.
You can also contact EPA's regional offices or the Safe Drinking Water Hotline at 800-426-
4791.
J. Are there opportunities for flexibility?
There are opportunities for systems to apply for variances and exemptions from the requirements
of this rule. You should contact your State to see what is necessary for approval. Also, the 1996
Amendments to the Safe Drinking Water Act allow for the use of point-of-use or point-of-entry
devices for compliance if the units are owned, controlled, and maintained by the public water
system or by a person under contract to the system to ensure proper operation and maintenance
and compliance with the MCL or treatment technique and the units are equipped with mechanical
warnings to ensure that customers are automatically notified of operational problems. Again, you
should contact your State for more information.
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IV. QUESTIONS AND ANSWERS ABOUT THE STAGE 1 DBPR
A. Am I in violation of the MRDL if I have to increase my chlorine or chloramine
concentration in the distribution system following a line break?
No. You are allowed to increase residual disinfectant levels in the distribution system above the
MRDLs for chlorine and chloramines (but not for chlorine dioxide) to a level and for a time
necessary to address specific microbiological contamination problems caused by circumstances
such as line breaks or cross-connection events. Compliance is not based on an individual
measurement, but on the average of all measurements taken over the previous year.
B. How do I conduct a self-audit of my drinking water system to help me evaluate whether
I am in compliance with the Stage 1 DBPR?
Since compliance is based on monitoring results, the best way to evaluate compliance is to
conduct monitoring prior to the compliance date in 2004 for any requirements that you will be
required to meet. This will allow you to evaluate your options for meeting requirements to
ensure compliance in 2004. Your options may include (but are not limited to) improved
operation of your existing treatment processes, modification of existing processes, or capital
improvements such as new technologies.
C. What are the implications of this rule for my existing permits?
You should contact the State to determine whether there are any implications.
D. How do I finance system improvements to comply with these regulations?
There are two major sources of Federal financial assistance available for water systems: the
Drinking Water State Revolving Fund (DWSRF) and the Water and Waste Disposal Loan and
Grant Program of the Rural Utilities Service (RUS) of the U. S. Department of Agriculture.
The 1996 SDWA Amendments authorized $9.6 billion for the DWSRF program. To date,
Congress has appropriated $4.2 billion, which includes $825 million for the program in Fiscal
Year 2001. By the end of September 2000, States had been awarded $3.2 billion in capitalization
grants and, from that, had provided more than $2.8 billion in assistance to eligible drinking water
systems. The Federal capitalization grant, together with State matching funds, is currently
making available about $1 billion per year. States have considerable discretion in designing their
DWSRF program, and have the option of offering special assistance to systems that the State
considers to be disadvantaged. Special assistance may include principal forgiveness, a negative
interest rate, an interest rate lower than that charged to non-disadvantaged systems, and extended
repayment periods of up to 30 years. Federal law allows DWSRF assistance to be provided to
both publicly- and privately-owned systems, although some States are unable or choose not to
provide assistance to privately-owned systems.
EPA recognizes that public water systems and States face a significant challenge in
implementing new requirements that are needed to ensure the continued provision of safe
drinking water. While the DWSRF program is proving to be a significant source of funding, it
IV-1
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cannot be viewed as the only source of funding. It will take a concerted effort on the part of
Federal, State and local governments, private business, and utilities to address the significant
infrastructure needs identified by public water systems. In order to ensure that the DWSRF
program is used to focus attention on the highest priority needs, all States must give priority to
those drinking water infrastructure improvement projects that will have the greatest public health
benefit or ensure compliance with SDWA. State DWSRF programs are currently making loans
available to the highest ranked projects on their lists and are also using a portion of the grants to
support other important drinking water program activities.
The RUS program is focused on providing a safe, reliable water supply and wastewater treatment
to residents of rural America. The program offers a combination of low interest loans and grants
to systems serving rural areas and cities and towns of up to 10,000 persons and which are
publicly owned (including Native American systems) or operated as not-for-profit corporations.
In recent years the RUS program has typically offered assistance totaling about $1.3 billion per
year, about 60% of which is directed to drinking water projects. Thus, about $780 million per
year is available for rural drinking water systems from this program. Together with the
approximately $1 billion per year being made available through the DWSRF, this results in a
total of about $1.78 billion per year of Federal financial assistance available for drinking water.
Other Federal financial assistance programs exist that may help systems with SDWA compliance
related expenditures. However, these other programs are not generally as large or focused on
drinking water as are the DWSRF and RUS programs. EPA's Environmental Financial Advisory
Board has developed a "Guidebook of Financial Tools", which offers a comprehensive summary
of public and private programs and mechanisms for paying for drinking water and other
environmental systems. The handbook is available through EPA's web site at:
http://www.epa.gov/efmpage/guidbk98/index.htm.
The Federal financial assistance programs described previously clearly face numerous,
competing demands on their resources. EPA's 1995 Drinking Water Infrastructure Needs
Survey identified a total 20-year need for all systems of $138.4 billion. The single largest
category of need (accounting for over half of the total need) is installation and rehabilitation of
transmission and distribution systems. Treatment needs constitute the second largest category of
need, accounting for over 1/4 of total needs. Storage and source rehabilitation and development
constitute the remaining major categories of needs. Thus, systems seeking financial assistance
for installation of DBF treatment are competing for resources with systems seeking assistance for
compliance with other rules and with systems seeking resources for basic infrastructure repair
and replacement. In seeking to meet these numerous and competing needs, the Agency
recognizes the importance of priority setting for financial assistance programs. Systems having
the financial capability to secure funding through the capital markets should do so, leaving the
Federal financial assistance programs to assist the truly needy systems. Since the demand for
assistance will likely outstrip the supply of assistance, you may want to discuss an exemption
with your State, which, if granted, will provide additional time for you to secure financial
assistance.
IV-2
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V. THE COMPLIANCE ASSURANCE PROCESS
A. How is my system's compliance with the Stage 1 DBPR requirements determined?
Compliance calculations are based on the results of the monitoring you are required to conduct
(see Section III for details). Some States conduct monitoring for small systems, either on a
regulatory basis or on a fee-for-service basis. You calculate compliance using the procedures
identified in Section III; States also may just require you to submit your analytical results and the
State will calculate compliance.
B. If I discover a violation, how can I work with my State to correct it?
If you discover that you have violated the Stage 1 Disinfectants and Disinfection Byproducts
Rule, you need to call the primacy agency (generally your State drinking water agency, but it may
be EPA or an approved tribe) to discuss the situation. The primacy agency is the entity which is
responsible for enforcing drinking water regulations.
You remain ultimately responsible for resolving the violation. However, if the violation can be
easily and expeditiously resolved, the primacy agency may be willing to work with you to
remedy the problem. If the cause of the violation is unknown, you may choose to work with the
primacy agency and/or a third-party contractor to determine how to correct the violation and
create a long-term compliance solution.
The primacy agency may issue a Notice of Violation (NOV), Administrative Order (AO), and/or
a Bilateral Compliance Agreement (BCA) notifying you of the violation and ordering you to
resolve the problem causing the violation(s). The primacy agency is authorized to demand a
penalty for any violation of the Stage 1 Disinfectants and Disinfection Byproducts Rule. Failure
to expeditiously remedy the cause of the violation(s) may result in a federal or State civil judicial
enforcement action demanding both injunctive relief and a significant penalty.
You may also be required to provide public notice and/or provide an alternate water source, such
as bottled water, if the violation impacts public health or may cause an imminent and substantial
endangerment to public health or the environment. Public notice means providing health impact
information to people who consume the water your system treats.
C. If EPA or the State discovers a violation, what might be its response?
To maximize compliance, EPA and States implement a balanced program of compliance
assistance, compliance incentives, and traditional law enforcement through the courts. Small
systems that must comply with complicated new statutes or rules often want to do the right thing,
but may lack the requisite knowledge, resources, or skills. Compliance assistance information
and technical advice helps small systems to understand and meet their obligations. Compliance
incentives, such as EPA's Small Business Policy, encourage persons to voluntarily discover,
disclose, and correct violations before they are identified by the government. A strong law
enforcement program protects all of us by targeting persons who neither comply nor cooperate to
address their problems.
V-l
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EPA and States use a variety of methods to determine whether systems are complying, including
inspecting facilities, reviewing records and reports, and responding to citizen complaints. If EPA
or a State learns that a system is violating the law, we may file an enforcement action seeking
penalties of up to $27,500, per violation, per day. The proposed penalty in a given case will
depend on many factors, including the number, length, and severity of the violations, the
economic benefit obtained by the violator, and its ability to pay. EPA has policies in place to
ensure penalties are calculated fairly. These policies are available to the public. In addition, any
system charged with a violation has the right to a public hearing.
In summary, EPA recognizes that we can achieve the greatest possible protection by encouraging
small systems to work with the State or us to discover, disclose, and correct violations. That is
why we have issued self disclosure, small business, and small community policies to eliminate or
reduce penalties for small and large entities that cooperate with EPA to address compliance
problems. In addition, we have established compliance assistance centers to serve over a million
small businesses. For more information on these and other programs for small businesses, please
contact the Small Business Ombudsman Clearinghouse/Hotline at 800-368-5888 (or 202-260-
1211 from the Washington, DC metropolitan calling area).
D. What is the legal status of the guide?
A judge can look at a compliance guide to help determine what penalty is appropriate or
reasonable. The content of the guide cannot otherwise be reviewed by the court.
In this compliance guide, we have tried to make clear what you must do to comply with the Stage
1 Disinfectants and Disinfection Byproducts Rule, as required by SBREFA. We hope you find
this presentation of regulatory requirements useful and the additional information helpful in
reaching and maintaining compliance.
V-2
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APPENDICES
A. Glossary of terms used in this guide
B. Where to obtain more information
C. Questionnaire - How useful was this guide?
D. Requirements for systems that use chlorine dioxide.
E. Requirements for systems that use ozone.
F. Requirements for systems that use conventional filtration treatment.
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APPENDIX A - GLOSSARY OF SELECTED TERMS USED IN
THIS GUIDE
Alternative compliance criteria means the eight criteria in the Stage 1 DBPR that systems may
use to demonstrate compliance with the disinfection byproduct precursor (TOC) removal
requirements in lieu of the requirement to remove specified levels of disinfection byproduct
precursors.
Conventional filtration treatment means a series of processes including coagulation, flocculation,
sedimentation, and filtration resulting in significant particulate removal.
Disinfection byproduct precursors means organic or inorganic compounds that react with
disinfectants to form disinfection byproducts.
Enhanced coagulation means the addition of sufficient coagulant for improved removal of
disinfection byproduct precursors by conventional filtration treatment.
Enhanced softening means the improved removal of disinfection byproduct precursors by
precipitative softening.
GAC10 means granular activated carbon filter beds with an empty-bed contact time of 10
minutes based on average daily flow and a carbon reactivation frequency of every 180 days.
Ground water under the direct influence of surface water (GWUDI) means any water beneath the
surface of the ground with significant occurrence of insects or other macroorganisms, algae, or
large-diameter pathogens such as Giardia lamblia or Cryptosporidium or significant and
relatively rapid shifts in water characteristics such as turbidity, temperature, conductivity, or pH
which closely correlate to climatological or surface water conditions. States were required to
determine whether ground water was under the influence of surface water for all systems by
1999.
Haloacetic acids (five) (HAAS) mean the sum of the concentrations in milligrams per liter of the
haloacetic acid compounds (monochloroacetic acid, dichloroacetic acid, trichloroacetic acid,
monobromoacetic acid, and dibromoacetic acid), rounded to two significant figures after
addition.
Maximum residual disinfectant level (MRDL) means a level of a disinfectant added for water
treatment that may not be exceeded at the consumer's tap without an unacceptable possibility of
adverse health effects. For chlorine and chloramines, a PWS is in compliance with the MRDL
when the running annual average of monthly averages of samples taken in the distribution
system, computed quarterly, is less than or equal to the MRDL. For chlorine dioxide, a PWS is
in compliance with the MRDL when daily samples are taken at the entrance to the distribution
system and no two consecutive daily samples exceed the MRDL. MRDLs are enforceable in the
same manner as maximum contaminant levels under the Safe Drinking Water Act. There is
convincing evidence that addition of a disinfectant is necessary for control of waterborne
microbial contaminants. Operators may increase residual disinfectant levels of chlorine or
A-l
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chloramines (but not chlorine dioxide) in the distribution system to a level and for a time
necessary to protect public health to address specific microbiological contamination problems
caused by circumstances such as distribution line breaks, storm runoff events, source water
contamination, or cross-connections.
Maximum residual disinfectant level goal (MRDLG) means the maximum level of a disinfectant
added for water treatment at which no known or anticipated adverse effect on the health of
persons would occur, and which allows an adequate margin of safety. MRDLGs are
nonenforceable health goals and do not reflect the benefit of the addition of the chemical for
control of waterborne microbial contaminants.
Pathogens means disease-causing organisms, such as some bacteria, viruses, and protozoa.
Subpart H systems means public water systems using surface water or ground water under the
direct influence of surface water as a source that are subject to the requirements of the Surface
Water Treatment Rule.
SUVA means Specific Ultraviolet Absorption at 254 nanometers (nm), an indicator of the humic
content of a water. It is a calculated parameter obtained by dividing a sample's ultraviolet
absorption at a wavelength of 254 nm (UV254) (in m"1) by its concentration of dissolved organic
carbon (DOC) (in mg/L).
Total Organic Carbon (TOC) means total organic carbon in mg/L measured using heat, oxygen,
ultraviolet irradiation, chemical oxidants, or combinations of these oxidants that convert organic
carbon to carbon dioxide, rounded to two significant figures.
A-2
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APPENDIX B - WHERE TO OBTAIN MORE INFORMATION
EPA has developed a series of guidance manuals to support the Stage 1 Disinfectants and
Disinfection Byproducts Rule. The manuals will aid EPA, State agencies, and you in
implementing the rule, and will help to ensure that implementation is consistent.
Guidance Manual for Enhanced Coagulation and Enhanced Precipitative Softening (EPA
815-R-99-012)
Objective: To assist utilities in implementing, monitoring, and complying with the treatment
technique requirements in the final Stage 1 Disinfectants and Disinfection Byproducts Rule and
to provide guidance to State staff responsible for implementing the treatment requirements.
Contents: The manual provides detailed information on the total organic carbon (TOC) removal
requirement; explains how to set an alternative TOC removal percentage under the Step 2
procedure; details monitoring, reporting, and compliance requirements; and discusses strategies
that can be employed to mitigate the potential secondary effects on plant performance due to
implementation of the treatment technique.
Alternative Disinfectants and Oxidants Guidance Manual (EPA 815-R-99-014)
Objective: To provide technical data and engineering information on disinfectants and oxidants
that are not as commonly used as chlorine, so that systems can evaluate options for developing
disinfection schemes to control water quality problems such as zebra mussels and Asiatic clams,
and oxidation to control water quality problems associated with iron and manganese.
Contents: The manual discusses six disinfectants and oxidants: ozone, chlorine dioxide,
potassium permanganate, chloramines, ozone/hydrogen peroxide combinations, and ultraviolet
light. A decision tree is provided to assist in evaluating which disinfectant(s) is most appropriate
given certain site-specific conditions (e.g., water quality conditions, existing treatment and
operator skill). The manual also contains a summary of existing alternative disinfectants used in
the United States and cost estimates for the use of alternative disinfectants.
M/DBP Simultaneous Compliance Manual (EPA 815-R-99-015)
Objective: To assist public water systems on complying simultaneously with various drinking
water regulations (e.g., Stage 1 Disinfectants and Disinfection Byproducts Rule, Interim
Enhanced Surface Water Treatment Rule, Lead and Copper Rule and the Total Coliform Rule).
The manual discusses operational problems you may encounter when implementing these rules.
Contents: The manual provides detailed information on the requirements in the Stage 1
Disinfectants and Disinfection Byproducts Rule and the Interim Enhanced Surface Water
Treatment Rule.
For more information, contact EPA's Safe Drinking Water Hotline, 1 (800) 426-4791, or see
the Office of Ground Water and Drinking Water web page at http://www.epa.gov/safewater/
standards.html. The rule is available at www.epa.gov/safewater/mdbp/dbpfr.html.
To order a copy of guidance manuals you may contact the Safe Drinking Water Hotline at (800)
426-4791 or you may download an electronic version from the OGWDW website at
http://www.epa.gov/safewater/mdbp/implement.html.
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APPENDIX C - QUESTIONNAIRE
Title of Rule or Program:
Name ofCommenter (optional):_
Please take a moment to let us know if you found this guide useful by answering the following
questions. Thank you; your feedback is important to us.
1. I could easily under stand what requirements I must meet._
2. The guide is written in understandable language.
3. The guide helped me understand the steps I must take to comply with the rule._
4. If you have suggestions to improve the guide, please indicate below.
Please fold on dashed line and return by mail. Thank you.
U.S. EPA
Regulatory Management Division
Mail Code 2136
1200 Pennsylvania Avenue, NW
Washington, DC 20460
C-l
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APPENDIX D. What do I have to do if I use chlorine dioxide?
Exhibit D-l What ROUTINE MONITORING must I conduct under the Stage 1 DBPR?
Chemical
Chlorite1
Chlorine
Dioxide
Frequency
Daily
1 3 -sample set per month
Additional: On any day
following any daily
sample that exceeds 1.0
mg/L, you must take a 3-
sample set
Daily
Additional: For any daily
sample that exceeds 0.8
mg/L, you must take 3
samples the following
day
Where monitoring must be conducted
Entrance to the distribution system.
Near first customer (1), location representative of average residence
time (1), location representative of maximum residence time in
distribution system (1).
Near first customer (1), location representative of average residence
time (1), location representative of maximum residence time in
distribution system (1). The system may use results to meet monthly 3-
sample set monitoring requirement if the monthly 3 -sample set has not
yet been taken.
Entrance to the distribution system.
• If chlorine dioxide or chloramines are used for residual disinfection
or chlorine with no booster chlorination is used for residual
disinfection: all samples as close as possible to the first customer at
intervals of at least 6 hours
• If chlorine with booster chlorination is used for residual disinfection:
one sample as close as possible to the first customer, one sample at a
location representative of average residence time, one sample as close
as possible to the end of the distribution system (reflecting maximum
residence time)
NOTES:
1 Not required for transient noncommunity water systems
Exhibit D-2 What REDUCED MONITORING may I conduct under the Stage 1 DBPR?
Chemical
Chlorite (daily)1
Chlorite
(monthly)1
Chlorine Dioxide
Frequency
No reduced monitoring allowed
1 3 -sample set per quarter
No reduced monitoring allowed
Where monitoring must
be conducted
NA
Near first customer (1),
location representative of
average residence time(l),
location representative of
maximum residence time in
distribution system. (1)
NA
Conditions for reduced
monitoring
NA
• No daily or monthly
sample has exceeded the
MCL and
• No additional monitoring
has been required and
• No quarterly sample
exceeds the MCL
NA
NOTES:
1 Not required for transient noncommunity water systems
D-l
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Exhibit D-3 How do I DETERMINE IF MY SYSTEM IS IN COMPLIANCE with the MCLs
andMRDLs of the Stage 1 DBPR?
Chemical
Compliance is based on...
Chlorite
Average of 3-sample sets.
• If arithmetic average of any 3-sample set in the month exceeds the MCL, the system is in
violation.
• The system must notify the public and report to the State if in violation.
Chlorine
Dioxide—
Acute
Violation
Consecutive daily samples collected.
• If any daily sample taken at entrance to distribution system exceeds 0.8 mg/L, and on the
following day one or more of the three samples taken in the distribution system exceeds 0.8
mg/L, the system is in acute violation.
• The system must take immediate corrective action to lower the level of chlorine dioxide below
0.8 mg/L, and within 24 hours notify the public and consult with the State.
• Failure to take samples in the distribution system following an exceedance of the MRDL at the
entrance to the distribution system is also an acute violation. System must, within 24 hours,
notify public of acute violation and consult with the State.
Chlorine
Dioxide—
Nonacute
Violation
Consecutive daily samples collected.
• If any two consecutive daily samples taken at entrance to distribution system exceed 0.8 mg/L,
and all distribution system samples are below 0.8 mg/L, the system is in nonacute violation.
• The system must take immediate corrective action to lower the level of chlorine dioxide
belowO.8 mg/L, notify the public and report to the State.
• Failure to take samples at the distribution system entrance following an exceedance of the
MRDL is also a violation. System must notify public of nonacute violation and report to the
State.
Exhibit D-4 What do I have to REPORT to the State under the Stage 1 DBPR?
Chemical
What must be reported1'2'3
Chlorite
Number of entry point samples taken each month for last three months
Location, date, result of each sample (both entry point and distribution system samples) taken
during last three months
For each month in the reporting period, the arithmetic average of all samples taken in each 3-
sample set taken in the distribution system
Whether MCL violations occurred, in which month(s) violations occurred, and how many times
MCL violations occurred each month
Chlorine
Dioxide
Dates, results, locations of samples taken during last quarter
Whether MRDL was exceeded
Whether MRDL was exceeded in any two consecutive daily samples and whether resulting
violation was acute or nonacute
NOTES:
1. Systems required to sample quarterly or more frequently must report to the State within 10 days after the end of
each quarter in which samples were collected.
2. Systems required to sample less frequently than quarterly must report to the State within 10 days after the end of
each monitoring period in which samples were collected.
3. The State may choose to perform calculations and determine whether the MCL, MRDL, or treatment technique
was met in lieu of having the system report that information.
D-2
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APPENDIX E. What do I have to do if I use ozone?
Exhibit E-l What ROUTINE MONITORING must I conduct under the Stage 1DBPR?
Chemical
Bromate
Bromide
Frequency
1 sample per ozone plant
per month
1 sample per ozone plant
per month
Where monitoring
must be conducted
Entrance to the distribution system.
In source water (only required if the
reduced bromate monitoring).
system wishes to qualify for
Exhibit E-2 What REDUCED MONITORING may I conduct under the Stage 1 DBPR?
Chemical
Bromate
Bromide
Frequency
1 sample per ozone plant per
quarter
No reduced monitoring if
wishing to conduct reduced
bromate monitoring
Where monitoring
must be conducted
Entrance to the
distribution system.
NA
Conditions for reduced
monitoring
• Annual average source water
bromide concentration <0.05 mg/L1
NA
NOTES:
1 System must base the initial qualification for reduced monitoring on at least one year's worth of monitoring and
must resume monthly bromate monitoring if running annual average of source water bromide • 0.05 mg/L.
Exhibit E-3 How do I DETERMINE IF MY SYSTEM IS IN COMPLIANCE with the bromate
MCL in the Stage 1 DBPR?
Chemical
Compliance is based on...
1,2
Bromate
Running annual arithmetic average, computed quarterly, of monthly samples (or average of
all samples taken during the month if more than 1 sample was collected).
• If average of samples covering any consecutive 4-quarter period exceeds the MCL, the system is
in violation.
• The system must notify the public and report to the State if in violation.
NOTES:
1. Where compliance is based on a running annual average of monthly or quarterly samples or averages and the
system's failure to monitor makes it impossible to determine compliance with the MCLs or MRDLs, this failure to
monitor will be treated as a violation for the entire period covered by the annual average.
2. All samples taken and analyzed under the provisions of the monitoring plan must be included in determining
compliance, even if that number is greater than the minimum required.
3. If during the first year of monitoring, any individual quarter's average will cause the running annual average of
that system to exceed the MCL, the system is out of compliance at the end of that quarter.
E-l
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Exhibit E-4 What do I have to REPORT to the State under the Stage 1 DBPR?
Chemical
Bromate
What must be reported1'2'3
• Number of samples taken during last quarter
• Location, date, result of each sample taken during last quarter
• Arithmetic average of monthly arithmetic averages of all samples
• Whether MCL was exceeded
taken in last year
NOTES:
1. Systems required to sample quarterly or more frequently must report to the State within 10 days after the end of
each quarter in which samples were collected.
2. Systems required to sample less frequently than quarterly must report to the State within 10 days after the end of
each monitoring period in which samples were collected.
3. The State may choose to perform calculations and determine whether the MCL, MRDL, or treatment technique
was met in lieu of having the system report that information.
E-2
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APPENDIX F. What do I have to do if I am a subpart H system
with conventional filtration treatment?
If you are a subpart H system with conventional filtration treatment, you must (a) remove organic
disinfection byproduct precursors (DBPP), measured as total organic carbon, through enhanced
coagulation or enhanced softening, (b) demonstrate that your DBPP cannot be removed through
these processes, or (c) demonstrate that the level or nature of your DBPP does not require their
removal.
There are many ways to achieve compliance with this requirement. You should review the
"Guidance Manual for Enhanced Coagulation and Enhanced Precipitative Softening "(EPA 815-
R-99-012), which is available as indicated in Appendix B of this manual. This guidance manual
will assist you in implementing, monitoring, and complying with the treatment technique
requirements in the Stage 1 Disinfectants and Disinfection Byproducts Rule. The guidance
manual provides detailed information on the total organic carbon (TOC) removal requirement;
explains how to set an alternative TOC removal percentage under the Step 2 procedure; details
monitoring, reporting, and compliance requirements; and discusses strategies that can be
employed to mitigate the potential secondary effects on plant performance due to implementation
of the treatment technique. Because the "Guidance Manual for Enhanced Coagulation and
Enhanced Precipitative Softening " is so detailed, its specific guidance is not repeated here.
Instead, you should review this appendix to determine whether the requirement applies to you. If
this requirement applies to you, you should refer to the guidance manual.
What is the goal of enhanced coagulation and enhanced precipitative softening?
The goal of enhanced coagulation and precipitaive softening is to provide additional removal of
the natural organic material (referred to as total organic carbon or "TOC") that is a precursor to
DBF formation. TOC and disinfectants commonly used in drinking water treatment can react to
form DBFs. Adding additional amounts of coagulant or lime to coagulation or softening
treatment trains, respectively, can increase the removal of TOC and thereby lower DBF levels in
finished water.
Which systems does the treatment technique apply to?
The treatment technique applies to subpart H systems (systems using surface water or
groundwater under the direct influence of surface water) that use conventional treatment.
Conventional treatment is defined as coagulation or lime addition, flocculation, sedimentation,
and filtration.
How is the treatment technique implemented?
Public water systems (PWSs) are required to remove a specified percentage of TOC from the
raw water. The percent removal is based on raw water TOC and alkalinity levels. A pair of TOC
samples must be taken simultaneously in the raw water and no later than the combined filter
effluent at least once per month to calculate the percent removal and demonstrate compliance via
a running annual average. If a PWS is unable to meet the required TOC removal, the State may
F-l
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set an alternative TOC percent removal based on jar or pilot testing that reflects the treatability
of their water. PWSs may also use one of the alternative compliance criteria to demonstrate
compliance.
What are alternative compliance criteria?
Some systems may have water that is low in DBPPs or have DBPPs that are non-reactive or
cannot be removed through enhanced coagulation or enhanced softening. For these systems,
EPA has designated different standards for demonstrating compliance, known as alternative
compliance criteria. There are six alternative compliance criteria that are available to all systems,
plus two more that are available only to systems that use precipitative softening. They are
discussed in detail in the "Guidance Manual for Enhanced Coagulation and Enhanced
Precipitative Softening".
Exhibit F-l What ROUTINE MONITORING must I conduct under the Stage 1 DBPR?
Chemical
Frequency
Where monitoring must be conducted
TOC and
Alkalinity
(conventional
treatment)
- Two TOC samples per plant
per month
- One alkalinity sample per
plant per month at same time as
source water TOC sample is
taken
TOC (two samples)
• In source water prior to any treatment
• No later than the point of combined filter effluent
turbidity monitoring and representative of filtered
water
Alkalinity
• Same location as source water TOC sample is taken.
Exhibit F-2 What REDUCED MONITORING may I conduct under the Stage 1 DBPR?
Chemical
Frequency
Where monitoring must be
conducted
Conditions for reduced
monitoring
TOC and
Alkalinity
(conventional
treatment)
- Two TOC samples
per plant per quarter
- One alkalinity
sample per plant per
quarter at same time
as source water TOC
sample is taken
TOC (two samples)
• In source water prior to any
treatment
• No later than the point of
combined filter effluent turbidity
monitoring and representative of
filtered water
Alkalinity
• Same location as source water
TOC sample is taken.
Average treated water TOC <
2.0 mg/L for 2 consecutive years
or <1.0 mg/L for 1 year
F-2
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Exhibit F-3 How do I DETERMINE IF MY SYSTEM IS IN COMPLIANCE with the TOC
removal requirements of the Stage 1 DBPR?
Chemical
TOC (conventional
treatment)
Compliance is based on...
"Step 1" or "Step 2" removal targets or alternative compliance criteria 1>2 Refer to
the "Guidance Manual for Enhanced Coagulation and Enhanced Precipitative
Softening" for further information.
NOTES:
1. Where compliance is based on a running annual average of monthly or quarterly samples or averages
and the system's failure to monitor makes it impossible to determine compliance with the treatment
technique, this failure to monitor will be treated as a monitoring violation for the entire period covered by
the annual average.
2. All samples taken and analyzed under the provisions of the monitoring plan must be included in
determining compliance, even if that number is greater than the minimum required.
F-3
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