United States       Office of Water      EPA 815-B-06-001
          linvironmcntal         (4601)        January 2006
          Protection Agency

<>EPA  INITIAL DISTRIBUTION SYSTEM

          EVALUATION GUIDE FOR SYSTEMS

          SERVING FEWER THAN 10,000 PEOPLE
          FOR THE FINAL STAGE 2 DISINFECTANTS
          AND DISINFECTION BYPRODUCTS RULE

-------
This page intentionally left blank.

-------
     Note on the Initial Distribution System Evaluation Guide for Systems
  Serving Fewer than 10,000 People for the Final Stage 2 Disinfectants and
                           Disinfection Byproducts Rule
Purpose:

       The purpose of this guidance manual is solely to provide technical information for small water
systems and states to assist them in complying with the Initial Distribution System Evaluation
(IDSE), a component of the Stage 2 Disinfectants and Disinfection Byproducts Rule (Stage 2 DBPR).
This guidance is not a substitute for applicable legal requirements, nor is it a regulation itself. Thus,
it does not impose legally-binding requirements on any party, including EPA, states, or the regulated
community. Interested parties are free to raise questions and objections to the guidance and the
appropriateness of using it in a particular situation.  Although this manual describes many methods
for complying with IDSE  requirements, the guidance presented here may not be appropriate for all
situations, and alternative  approaches may provide satisfactory performance. The mention of trade
names or commercial products does not constitute endorsement or recommendation for use.
Authorship:

      This manual was developed under the direction of EPA's Office of Water, and was
prepared by The Cadmus Group, Inc. and Malcolm Pirnic, Inc.  Questions concerning this
document should be addressed to:

Elin Warn Bctanzo and Thomas Grubbs
U.S. Environmental Protection Agency
Mail Code 4607M
1200 Pennsylvania Avenue NW
Washington, DC 20460-0001
Tel: (202) 564-1807 (Elin Warn Betanzo)
(202) 564-5262 (Thomas Grubbs)
Fax: (202) 564-3767
Email: Bctanzo.Elinra.cpamail.epa.gov and Grubbs.Thomasfo.cpamail.cpa.gov
 IDSE Guide for Systems Serving < 10,000           i                                January 2006

-------
Acknowledgments:

American Water Works Association
Association of Metropolitan Water Agencies
Association of State Drinking Water Agencies
Ken Bousfield—Utah Division of Drinking Water
Andrew DeGraca—San Francisco Water
Walter Grayman—W.M. Grayman Consulting
Mike Grimm—Oregon Health Department
Rich Haberman—California Department of Health Services
Mike Hotaling—City of Newport News
Doug Howie—HDR  Engineering
Alexa Obolensky—Philadelphia Water Department
David Reckhow—University of Massachusetts, Amherst
Tom Schaeffer—Association of Metropolitan Water Agencies
Charlotte Smith—Charlotte Smith & Associates
Scott Summers—Colorado University
Jeffrey Swcrtfegcr-Cincinnati Water Works
Jim Ubcr—University of Cincinnati
Marguerite Young—Clean Water Action
 1DSE Guide- for Systems Sen-ing < 10,000           ii                                Janumy 2006

-------
                                      Contents
List of Exhibits	  v
List of Examples 	  v
List of IDSE Forms	  v
List of Worksheets	  v
Acronyms	vi
Definitions	  vii

1.0 Introduction	1-1
1.1    Getting Started	
      1.1.1   What is the IDSE? What is its purpose?	
       1.1.2  Do I have to conduct an IDSE?	
       1.1.3  What guidance materials are available for the IDSE?
       1.1.4  How can I get copies of EPA guidance materials?  ..
       1.1.5  How do I use this guidance manual?	
 .2    Overview of IDSE Options
                                                                                    -1
                                                                                    -2
                                                                                    -4
                                                                                    -4
                                                                                    -5
1.3    Early Implementation Process	1-5

2.0 Determining Your IDSE Schedule and Option	2-1
2.1    System Characteristics that Affect IDSE Requirements	2-1
2.2    Determining Your IDSE Schedule	2-1
2.3    Determining Your IDSE Option  	2-4
2.4    IDSE Requirements Summary Sheets	2-4

3.0 Very Small System Waiver	3-1
3.1    Qualifying for the VSS Waiver	3-1
3.2    Selecting a Stage 2 DBPR Compliance Monitoring Site	3-2
3.3    Next Steps: Preparing the Stage 2 DBPR Compliance Monitoring Plan  	3-2

4.0 40/30 Certification  	4-1
4.1    Qualification Criteria .	4-2
4.2    Preparing and Submitting the Certification Letter	4-3
4.3    Recordkeeping	4-6
4.4    Selecting Stage 2 Compliance Monitoring Sites	4-6
       4.4.1  You I lave THE SAME Number of Stage 1 Sites as Required by the Stage 2 DBPR
             	4-7
       4.4.2  You Have MORE Stage 1 Sites than Required by the Stage 2 DBPR 	4-7
       4.4.3  You Have FEWER Stage 1  Sites than Required by the Stage 2 DBPR  	4-7
4.5    Next Steps: Preparing the Stage 2 DBPR Compliance Monitoring Plan  	4-8

5.0 Standard Monitoring	5-1
5.1    Selecting Standard Monitoring Sites and Preparing Your Standard Monitoring Plan  . .  5-2
       5.1.1  Recommended Approach for Selecting Standard Monitoring Sites 	5-3
             Step 1: Gather Data and Tools  	5-5

IDSE Guide for Systems Sen'ing < 10,000           Hi                                January 2006

-------
             Step 2: Identify Near Entry Point Standard Monitoring Sites (For Consecutive
                    Systems Only) 	5-6
             Step 3: Identify Candidate Average Residence Time Sites  	5-7
             Step 4: Identify Candidate High TTHM Sites  	5-9
             Step 5: Identify Candidate High HAA5 Standard Monitoring Sites  	5-10
             Step 6: Plot Sites on a Distribution System Map  	5-11
             Step 7: Select Standard Monitoring Sites from Candidate Sites  	5-11
             Step 8: Write Justifications and a Summary of Data 	5-12
       5.1.2  Selecting Your Peak Historical Month and Determining Standard Monitoring
             Schedule	5-14
       5.1.3  Preparing Your Standard Monitoring Plan 	5-16
5.2    Conducting Standard Monitoring  	5-27
5.3    Selecting Stage 2 DBPR Compliance Monitoring Sites and Preparing the IDSE
       Report	5-28
       5.3.1  Selecting Stage 2 DBPR Compliance Monitoring Locations  	5-29
       5.3.2  Determining Your Stage 2 DBPR Compliance Monitoring Schedule  	5-30
       5.3.3  Preparing the IDSE Report for Standard Monitoring 	5-31
5.4    Recordkeeping	5-43
5.5    Next Steps: Preparing the Stage 2 DBPR Compliance Monitoring Plan  	5-43
                                     Appendices
Appendix A  Consecutive and Wholesale System Issues	 A-1

Appendix B  Example IDSE Standard Monitoring Plan and Report for a Surface Water System
             Serving 6,000 People	 B-l
IDSE Guide for Systems Serving < 10,000           iv                                January 2006

-------
                                   List of Exhibits

Exhibit 1.1  IDSE Tool Home Page	1-3
Exhibit 1.2 Organization of the IDSE Guide for Systems Serving < 10,000	1-4
Exhibit 1.3 Options for Submitting IDSE Material to EPA and States Through the IPMC .... 1-6

Exhibit 2.1  IDSE Schedule Number	2-2
Exhibit 2.2 Example Letter from EPA to System on Schedule 1	2-3
Exhibit 2.3 Flowchart for Determining Your IDSE Option	2-5
Exhibit 2.4 List of Requirements Summary Sheets  	2-7

Exhibit 4.1  40/30 Criteria Compliance Dates	4-2
Exhibit 4.2 Required Contents of Stage 2 DBPR Compliance Monitoring Plans 	4-9

Exhibit 5.1  Required Elements of Your Standard Monitoring Plan	5-2
Exhibit 5.2 IDSE Standard Monitoring Requirements	5-3
Exhibit 5.3 Recommended Approach to Selecting Standard Monitoring Sites	5-4
Exhibit 5.4 Data and Tools for Selecting Different Types of Standard Monitoring Sites	5-6
Exhibit 5.5  Guidelines for Using Disinfectant Residual Data  	5-8
Exhibit 5.6 Required Elements of Your IDSE Report for Standard Monitoring	5-29
Exhibit 5.7 Required Contents of Stage 2 DBPR Compliance Monitoring Plans 	5-44
                                  List of Examples

Example 2.1 Determining IDSE Requirements for a Consecutive System Serving 4,000
             People	2-6
Example 4.1 Qualifying for a 40/30 Certification	4-3
Example 4.2 Completed 40/30 Certification Letter Form  	4-5
                                List of IDSE Forms

40/30 Certification Letter Form  	4-4
Standard Monitoring Plan Form for Systems Serving < 10,000	5-21
IDSE Report for Standard Monitoring for Systems Serving < 10,000  	5-37
                                List of Worksheets

Worksheet 5.1  Selecting the Peak Historical Month 	5-15
IDSE Guide for Systems Serving < 10,000           v                                January 2006

-------
                                    Acronyms

CBI          Confidential Business Information
CWS         Community water system
DBF         Disinfection byproduct
DBPR       Disinfectants and Disinfection Byproducts Rule
EPA         U.S. Environmental Protection Agency
FOIA        Freedom of Information Act
G WUDI      Ground water under the direct influence of surface water
HAA   '      Haloacetic acid
HAAS       The sum of five HAA species
HPC         Heterotrophic plate count
IDSE         Initial distribution system evaluation
IPMC        Information Processing and Management Center
LRAA       Locational running annual average
LT2ESWTR  Long Term 2 Enhanced Surface Water Treatment Rule
MCL         Maximum contaminant level
NTNCWS    Nontransient noncommunity water system
PWS         Public water system
PWSID      Public water system identification number
SDWA       Safe Drinking Water Act
SSS          System-specific study
STEP        Simple Tools for Eiffcctivc Performance
TCR         Total Coliform Rule
THM         Trihalomcthanc
TOC         Total organic carbon
TNCWS      Transient noncommunity water system
TTHM       Total trihalomcthancs
UV          Ultraviolet light
VSS         Very small system
IDSE Guide for Systems Serving < 10,000
VI
                                 Januan' 2006

-------
                                      Definitions

Biodegradation: a biological process where HAASs arc broken down into smaller compounds by
microbes.

Booster disinfection: the practice of adding disinfectant in the distribution system to maintain
disinfectant residual concentration throughout the distribution  system.

Combined distribution system: the interconnected distribution system consisting of the
distribution systems of wholesale systems and of the consecutive systems that receive finished
water. 40 CFR 141.2

Community water system: a public water system which serves at least 15 service connections used
by year-round residents or regularly serves at least 25 year-round residents. 40 CFR 141.2

Consecutive system: a public water system that receives some or all of its finished water from one
or more wholesale systems. Delivery may be through a direct  connection or through the
distribution system of one or more consecutive systems.  40 CFR 141.2

Disinfectant: any oxidant, including but not limited to chlorine, chlorine dioxide, chloramines,
and ozone added to water in any part of the treatment or distribution process, that is intended to
kill or inactivate pathogenic microorganisms. 40 CFR 141.2

Disinfectant residual concentration: the concentration of disinfectant that is maintained in a
distribution system. Disinfectant could be free chlorine (the sum of the concentrations of
hypochlorous acid (HOCI) and hypochloritc  (OC1)) or combined chlorine (chloramines).  It is
used in Surface Water Treatment Rule as a measure for determining CT.

Disinfection: a process which inactivates pathogenic organisms in water by chemical oxidants or
equivalent agents. 40 CFR 141.2

Disinfection byproduct (DBF): compound formed from the reaction of a disinfectant with organic
and inorganic compounds in the source or treated water during disinfection and distribution.

Dual Sample set: a set of two samples collected at the same time and same  location, with one
sample analyzed for TTHM and the other sample analyzed for HAA5. Dual sample sets are
collected for the purpose of conducting an IDSE under subpart U and determining compliance
with the TTHM and HAAS MCLs under subpart V.  40 CFR 141.2

Entry Point: the point(s) where finished water first enters the distribution system  from one or
more sources.  Samples taken at these points represent minimum residence time in the distribution
system.

Finished Water, water that is introduced into the distribution system of a public water system and
is intended for distribution and consumption  without further treatment, except as  treatment

IDSE Guide for Systems Serving < 10,000           riiJanuary 2006

-------
necessary to maintain water quality in the distribution system (e.g., booster disinfection, addition
of corrosion control chemicals).  40 CFR 141.2

Ground water system: public water systems that use ground water only or purchase ground water
from other systems (40 CFR 141.2).  For the purposes this guidance manual, ground water
systems refers to the subset of systems that disinfect their water, or purchase disinfected ground
water, even if they do not apply any additional treatment.

Ground water under the direct influence of surface water (GWUDI): 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 relative
rapid shifts in water characteristics such as turbidity, temperature, conductivity, or pH which
closely correlate to climatological or surface water conditions.  Direct influence must be
determined for individual sources in accordance with criteria established by the State.  The State
determination of direct influence may be based on site-specific measurements of water quality
and/or documentation of well construction characteristics and geology with field evaluation. 40
CFR 141.2

Haloacetic acid (HAA): one of the family of organic  compounds named as a derivative of acetic
acid, wherein one to three hydrogen atoms in the methyl group in acetic acid are each substituted
by a halogen atom (namely, chlorine and bromine) in the molecular structure.

Haloacetic acids (five) (11AA5): the  sum of the concentrations in milligrams per liter of the
haloacctic acid compounds (monochloroacctic acid, dichloroacctic acid, trichloroacctic acid,
monobromoacclic acid, and dibromoacetic acid), rounded to two significant figures after addition.
40 CFR 141.2

Heterotrophic plate count (HPC): a procedure for estimating the number of hcterotrophic bacteria
in water, measured as the number of colony forming  units per 100 mL.

Information Processing and Management Center (1PMC): a  receiving, processing, and mailing
facility with a web-based data management system that allows EPA and states to access, track,
and respond to IDSE submissions.

Locational running annual average (LRAA):  the average of sample results taken at a particular
monitoring location during the previous four calendar quarters.  40 CFR  141.2

Maximum contaminant level (MCL):  the maximum permissible level of a contaminant in water
which is delivered to any user of a public water system.  40 CFR 141.2

Maximum contaminant level goal (MCLG): the maximum level of a contaminant in drinking
water at which no known or anticipated adverse effect on the health of persons would occur, and
which allows an adequate margin of safety. Maximum contaminant level goals are
nonenforceablc health goals. 40 CFR 141.2
IDSE Guide jor Systems Serving < 10,000           viii                                 January 2006

-------
 Mixing Zone: an area in the distribution system where water flowing from two or more different
 sources blend.

 Monitoring site: the location where samples are collected.

 Non-community water system: a public water system that is not a community water system. A
 non-community water system is either a "transient non-community water system (TNCWS)" or a
 "non-transient non-community water system (NTNCWS) 40 CFR 141.2

 Non-transient non-community water system (NTNCWS): a public water system that is not a
 community water system and that regularly serves at least 25 of the same persons over 6 months
 per year. 40 CFR 141.2

 Population served: the retail number of people served by a water system.  Systems typically work
 with their State to determine population served for compliance purposes. Note that IDSE and
 Stage 2 compliance monitoring requirements (e.g., number of samples and sampling frequency)
 are based on the population served by the water system. IDSE and Stage 2 compliance
 monitoring schedules, however, are based on the largest population served by systems in the
 combined distribution system.  If you do not know the population of your system, ask your state.

 Public water system (PWS): a system for the provision to the public of water for human
 consumption through pipes or, after August 5, 1998, other constructed conveyances, if such
 system has at least fifteen service connections or regularly serves an average of at least twenty-
 five individuals daily at least 60 days out of the year.  Such term includes: any collection,
 treatment, storage, and distribution facilities under control of the operator of such system and
 used primarily in connection with such system; and any collection or prctrcatmcnt storage
 facilities not under such control which are used primarily in connection with such system.  Such
 term docs not include any "special irrigation district." A public water system is cither a
 "community water system" or a "noncommunity water system. 40 CFR 141.2

 Residence time: the time period lasting from when the water is treated to a particular point in the
 distribution system.  Also referred to as water age.

 Residual disinfection: also referred to as "secondary disinfection." The process whereby a
 disinfectant (typically Chlorine or Chloramines) is added to finished water in order to maintain a
 disinfection residual in the distribution system.

 State: the agency of the State or Tribal government which has jurisdiction over public water
 systems.  During any period when a State or Tribal government does not have primary
 enforcement responsibility pursuant to Section 1413 of the Safe Drinking Water Act, the term
 "State" means the Regional Administrator, U.S. Environmental Protection Agency.  40 CFR
 141.2
IDSE Guide for Systems Sewing < 10.000            ix                                 Januaiy 2006

-------
Subpart H systems: public water systems using surface water or ground water under the direct
influence of surface water as a source that arc subject to the requirements of 40 CFR 141.2 (H).
40CFR 141.2

Surface water: all water which is open to the atmosphere and subject to surface runoff. 40 CFR
141.2

Total chlorine residual: the sum of combined chlorine (chloramine) and free available chlorine
residual.

Total trihalomethanes (TTHM): the sum of the concentration in milligrams per liter of the
trihalomethane compounds (trichloromethane [chloroform], dibromochloromethane,
bromodichloromethane, and tribromomethane [bromoform]), rounded to two significant figures.
40 CFR 141.2

Tracer study: a procedure for estimating hydraulic properties of the distribution system, such as
residence time. Where more than one water source feeds the distribution system, tracer studies
can be used to determine the zone of influence of each source.

Transient Non-Community Water System (TNCWS) - a non-community water system that docs not
regularly serve at least 25 of the same persons over six months per year. 40  CFR 141.2

Trihalomethane (THM): one of the family of organic compounds named as  derivatives of
methane, wherein three of the four hydrogen atoms in methane are each substituted by a halogen
atom in the molecular structure. 40 CFR 141.2

Water distribution system model: a computer program that can simulate the  hydraulic, and in
some cases, water quality behavior of water in a distribution system.

Wholesale system: a public water system that treats source water as necessary to produce finished
water and then delivers some or all of that finished water to another public water system.
Delivery may be through a direct connection or through the distribution system of one or more
consecutive systems. 40 CFR  141.2
IDSE Guide for Systems Serving < 10,000           x                                 January 2006

-------
                                  1.0 Introduction
      This chapter covers:

             1.1    Getting Started (Read this Section First)
             1.2    Overview of IDSE Options
             1.3    Early Implementation Process
       The Administrator of the EPA signed the Stage 2 Disinfectants and Disinfection
Byproducts Rule (DBPR) on December 15,2005 and it was published in the Federal Register on
January 4, 2006 (71 FR 388). This rule applies to all community and non-transient
noncommunity water systems that provide disinfected water (other than water disinfected only
by Ultraviolet [UV] light) to their customers.  The rule has two primary sections. Subpart U is
referred to as the Initial Distribution System Evaluation (IDSE) section.  The requirements of
this part of the rule are discussed in this manual.  Subpart V, the Stage 2 Disinfection Byproducts
Requirements, is referred to as Stage 2 Compliance Monitoring in this guidance manual.  Stage 2
Compliance Monitoring Requirements are an extension of the Stage 1 DBPR. Note that systems
that arc exempt from the IDSE portion of the rule may  not be exempt from the Stage 2
Compliance Monitoring section.

       EPA developed this Initial Distribution System Evaluation (IDSE) Guide for Systems
Serving < 10,000 People to help these small systems meet the IDSE requirements of the  Stage 2
DBPR.  System personnel should start  by reading Section  1.1 to answer basic questions about
the IDSE, select the appropriate guidance materials to meet IDSE requirements, and get
instructions on how to use this manual.
1.1    Getting Started       ^»    Read this Section First
1.1.1   What is the IDSE? What is its purpose?

       IDSEs are an important part of the Stage 2 DBPR. They are one-time studies conducted
by water systems to identify distribution system locations with high concentrations of
trihalomethanes (THMs) and haloacetic acids (HAAs). Water systems will use results from the
IDSE, in conjunction with their Stage 1 DBPR compliance monitoring data, to select compliance
monitoring locations for the Stage 2 DBPR.

1.1.2   Do I have to conduct an IDSE?

       Community water systems (CWS) serving fewer than  10,000 people are subject to the
IDSE requirements of the Stage 2 DBPR if they use a primary or residual disinfectant other than
IDSE Guide for Systems Sei-ving < 10,000           1-1                               January 2006

-------
ultraviolet light (LJV), or are a consecutive system that delivers water that has been treated with a
primary or residual disinfectant other than LIV.

       IDSE requirements do not apply to NTNCWSs serving fewer than 10,000 people,
although these systems have other requirements under the Stage 2 DBPR.  Transient non-
community water systems (TNCWSs) arc not subject to any part of the Stage 2 DBPR.

       There are four options systems can use to comply with the IDSE requirements of the
Stage 2 DBPR:

       •   Qualify for a Very Small System (VSS) Waiver
       •   Meet 40/30 Certification requirements
       •   Conduct Standard Monitoring
          Conduct a System Specific Study (SSS) using existing monitoring results or a
          distribution system hydraulic model

       The first three options are described briefly in Section 1.2 of this chapter, with further
details provided in the remainder of this guidance manual. Because small systems arc less likely
to conduct an SSS, this option is not covered in this guidance manual. However, if interested,
you can find information about this option in other materials discussed below.

1.1.3   What guidance materials are available for the IDSE?

       EPA has developed two guidance manuals and an on-line tool to help you comply with
the IDSE requirement.  The manual you arc reading is targeted to smaller systems and focuses  on
information they arc most likely to use.  It covers VSS waivers, 40/30 certifications for systems
with low DBF  levels, and standard monitoring. As mentioned previously, this manual does not
discuss the SSS option of the IDSE.

       In addition to this IDSE Guide for Systems Serving < 10,000 People, EPA has developed
the The Initial Distribution System Evaluation (IDSE) Guidance Manual. The IDSE Guidance
Manual is comprehensive and contains technical guidance for all system sizes and types and all
IDSE options (including System Specific Studies).  If you already have extensive TTHM and
HAAS monitoring results and/or a hydraulic model of your distribution system, you  should read
the IDSE Guidance Manual to determine if you qualify for the SSS option to meet IDSE
requirements.

       EPA has also developed the IDSE Tool, available on-line at
http://www.epa.jpv/safewater/disinfection/stage2 and on CD. The IDSE tool walks systems
through the entire IDSE process, and it can be used in place of the  IDSE guidance manuals.  It
contains a Wizard you can use to determine your requirements and select the best IDSE option
for your system.  The tool then creates Custom Forms for your system size and type that can be
submitted electronically for EPA or state review.  See Section 1.3 for more information. Exhibit
1.1 shows the IDSE Tool home page.
IDSE Guide for Systems Serving < 10,000           1-2                                January 2006

-------
                                    Exhibit 1.1  IDSE Tool Home Page
                      ;$slij|j^if!!||J
                                                                                                         Help
                                                                                                                  I Print
^p|«|:|ir|3«^
If you prefer lo work offline, you can download
a desktop version of the IDSE Tool However,
the desktop version has limited functionality
0 e general information about your system
will not be automatically filled in, you cannot
submit completed plans and/or reports
online) To download the desktop version,
clicl- hep
                                     Instructions:
                                     The IDSE Tool provides you with the ability to determine what, if any, IDSE Requirements apply to your Public
                                     Water System If you already know which IDSE option is best for your system, select the Plan/Report Entry
                                     button below If you are not sure what your requirements are or which IDSE option is best for you, then select
                                     the Begin Wizard button
                                     You should have your schedule information letter sent by EPA or their State with you while going through the
                                     IDSE Wizard as some questions refer to the letter Systems that EPA or the State anticipate are on schedules
                                     1 or 2 should receive a letter in January 2QD6 Systems that EPA or the  State anticipate are on schedules 3 or
                                     4 should receive a letter in July 2006 if you did not receive a latter, you can still use the IDSE Tool However, if
                                     you buy or sell water (i e  you are part of a combined distribution system), you will need to call EPA or your
                                     state to determine your compliance schedule for the IDSE To identify your point of contact, clicn  here

                                     NOTE You will not be able to go back to a previous question once you have answered a question It you feel
                                     that you have answered a question incorrectly or if you would like to work through the wizard more than one e.
                                     click the  Home button to begin the wizard again
                                      Go To Plan/Report Entry
                                      (I know what my requirements are)

                                      ft you know which plan .ind / or report you would like
                                      to fill out. select the button belowto go directly to
                                      the Plan/Report Entry portion of the IDSE Tool You
                                      will be taken to the CD;: login page  If you have an
                                      uKic-ting CDX account, please login  If you are a new
                                      ii',fi, select "register with CD:™ to cieate a
                                      usprname and passwoid This login ensuies the
                                      intuimation you submit is r.ecure, and also allows
                                      you to save your work so you donl have lo complete
                                      your entire plan or report all at once
Go To Wizard
(I am not sure what my requirements are)

The wizard will help you determine if the IDSE
requirements apply to youi system and if so, what
you have to do to meet the requirements The wizard
will ask you a series of questions Based on youi
response the wizard will determine the nest question
as well as which requirements apply to you Dncf
completed, the wizard will provide you with a results
scieen that will display youi schedule and the best
IDSE option for youi system based on youi
responses You will also be able to continue to the
Plan/Report Entry portion from the results screen
Click the button belowto begin
           This IDSE Guide for Systems Serving < 10,000 People, the IDSE Guidance Manual, and
  the IDSE Tool address only IDSE requirements and DO NOT cover other provisions of the Stage
  2 DBPR.  For additional guidance on implementing the Stage 2 DBPR, you can refer to the
  following EPA materials:

           •    The Stage 2 DBPR Quick Reference Guide

           •    Stage 2 Disinfectant and Disinfection Byproducts Rule: Small Entity Compliance Guide
               One of the Simple  Tools for Effective Performance (STEP) Guide Series (draft version)

  EPA will be releasing draft versions of additional Stage 2 DBPR guidance manuals soon,
  including  The Consecutive Systems  Guidance Manual,  The Simultaneous Compliance Guidance
  Manual, and The Operational Evaluation Guidance Manual.  Your state may have additional,
  state-specific  materials to assist you in complying with the Stage 2 DBPR.
  IDSE Guide for Systems Serving < J 0,000
                                                          1-3
                        Januarv 2006

-------
1.1.4   How can I get copies of EPA guidance materials?

       •   You can download guidance manuals and fact sheets from EPA's Web site at
          httn: 'wwv, .ena.am 'Safc\vaterdisinfcctiotvstaue2.

       •   You can call the Safe Drinking Water Hotline at 1-800-426-4791

       •   You can call the National Service Center for Environmental Publications at 1-800-
          490-9198 or visit their Web site at http://www.cpa.gov,'nccpihom.

Also, you may wish to contact your state drinking water program office for additional guidance.

1.1.5   How do I use this guidance manual?

          To help you find information quickly, EPA has designed this manual in a modular
format. Exhibit 1.2 lists the chapters and appendices in this manual. Chapters 1 and 2 contain
information for all systems. After reading Chapter 1, you should go to Chapter 2 to determine
your 1DSE schedule and option using the flowchart in Exhibit 2.3. Chapter 2 also contains
requirements summary sheets for your 1DSE option and schedule. These sheets contain
compliance deadlines for IDSE submissions and other important information.  You should make
a copy of your requirements summary shcct(s) and keep them handy throughout the IDSE
process.

       After you have determined your IDSE option and schedule, you only need to refer to
Chapter 3, 4, or 5 of this manual for guidance on all of your IDSE requirements. If you arc a
consecutive or wholesale system, you should refer to Appendix A for specific issues that you
should consider.
     Exhibit 1.2  Organization of the IDSE Guide for Systems Serving < 10,000

 Chapter I          Introduction
 Chapter 2          Determining Your IDSE Schedule and Option
 Chapter 3*         Very Small System Waiver
 Chapter 4*         40/30 Certification

 Chapter 5*         Standard Monitoring
 Appendix A        Consecutive and Wholesale System Issues
 Appendix B        Example IDSE Standard Monitoring Plan and Report for a Surface Water
                   System Serving 6,000 People
* You need one of these Chapters for the IDSE
Note: Technical appendices related to DBF formation and TTHM and HAAS sampling protocol as well
as Stage 2 and LT2ESWTR compliance schedules are available in the IDSE Guidance Manual.


IDSE Guide for Systems Serving < 10.000          1-4                                January 2006

-------
 1.2    Overview of IDSE Options

       There are four options available to systems to meet IDSE requirements. Your option will
 depend on your technical resources, existing monitoring results, size, and preference.

       •   Very Small System (VSS) Waiver. Systems serving fewer than 500 people that
          have TTHM and HAAS data automatically receive the VSS waiver unless they are
          notified by EPA or their state that they must conduct an IDSE.  Systems receiving the
          VSS waiver have no further IDSE requirements.

           40/30 Certification.  Systems can fulfill the IDSE requirements by certifying that all
          individual TTHM and HAAS monitoring results for compliance with the Stage 1
          DBPR are less than or equal to 0.040 mg/L for TTHM and 0.030 mg/L for HAAS
          during a prescribed 2-ycar time period. In addition, the system must not have had any
          Stage  1 DBPR monitoring violations for TTHM and HAAS during the same period.
          The system must submit the required 40/30 certification and, unless told otherwise by
          EPA or their state, they have no further requirements under the IDSE.

       •   Standard Monitoring. Any system can choose to conduct standard monitoring, even
          if they receive a VSS or qualify for the 40/30 certification. Standard monitoring
          entails 1 year of distribution system monitoring at multiple locations (in addition to
          Stage  1 DBPR monitoring). The required sampling frequency and minimum number
          of sample locations depend on population served and source water type.  Systems
          conducting standard monitoring must prepare a standard monitoring plan and IDSE
          report.

          System Specific Study (SSS).  Systems can meet IDSE requirements using existing
          monitoring results or a hydraulic model if their data or model meet certain minimum
          criteria.  Systems conducting an SSS must prepare an SSS plan and IDSE report.
          Refer to the IDSE Guidance Manual if you are considering this option.
1.3    Early Implementation Process

       Because IDSE activities begin soon after the Stage 2 DBPR is finalized, EPA and states
will be working together to implement the IDSE. To facilitate review and processing of IDSE
submissions, EPA has created the Information Processing and Management Center (IPMC).
The IPMC is both a receiving facility and a web-based data management system that allows EPA
and states to access, track, and respond to IDSE submissions.

       The IPMC is password protected and accessible only by EPA and state drinking water
representatives. IDSE submissions will not, however, be considered confidential business
information (CBI) and are subject to the Freedom of Information Act (FOIA). Therefore, your
IDSE submissions should not contain information that poses a security risk to your system.
Chapter 5 of this manual provide guidelines on the kinds of information you may want to
exclude from your distribution system schematic for security reasons.
IDSE Guide for Systems Serving < 10,000           1-5                               January 2006

-------
      One advantage of the IPMC is that it provides a one-stop location for IDSE submissions.
Regardless of whether EPA or your state is reviewing your IDSE materials, all submissions go to
the same address. Sec Exhibit 1.3 for ways in which you can submit IDSE materials to the
IPMC.
       If you have questions during the IDSE, you should visit EPA's website at
http://wwvv.cpa.gov/safcwatcr disinfection-'stagc2 to determine the contact name
and phone number for the IDSE for your state. You can also call the Safe
Drinking Water Hotline at 1-800-426-4791 for this information.
 Exhibit 1.3 Options for Submitting IDSE Material to EPA and States Through the
                                       IPMC
           Option 1
       Option 2
         Option 3
      Use the IDSE Tool
      to submit completed
    certifications, plans and
      reports electronically
  Mail paper copies of
    submissions to:

    STAGE 2 DBPR
    US EPA-IPMC
      P O Box 98
Dayton, OH 45401-0098
E-mail electronic submissions
     as attachments to:

   stage 2mctop(a)epa.qov
Note:
1. You can use one of these three options to submit IDSE materials to the IPMC
      The IPMC accepts a variety of electronic formats:

          •   Adobe PDF file (*.pdf)
          •   Microsoft Word (*.doc)
          •   WordPerfect (*.wpd)
          •   Image files (*.gif, *.bmp, *.jpg, *.jpeg)
          •   Microsoft Excel (*.xls)
          •   Text file (*.txt)
IDSE Guide for Systems Sewing < 10,000
         1-6
                 Januan' 2006

-------
                2.0 Determining Your IDSE Schedule and Option
      This chapter covers:

            2.1    System Characteristics that Affect IDSE Requirements
            2.2    Determining Your IDSE Schedule
            2.3    Determining Your IDSE Option
            2.4    IDSE Requirements Summary Sheets
2.1    System Characteristics that Affect IDSE Requirements

       Your IDSE schedule, option, and other requirements depend on your system
characteristics. In general, there are three system characteristics that drive IDSE requirements:

       •   Whether you arc a subpart H system or a ground water system.

       •   The population served by your system.

          If you arc a consecutive or wholesale system, the population served by the largest
          system in your combined distribution system.

Regulatory definitions for subpart H systems, consecutive systems, wholesale systems, and
combined distribution systems arc provided in the definitions section  at the beginning of this
guidance manual. Appendix A provides additional discussion of important definitions for
consecutive and wholesale systems.
2.2    Determining Your IDSE Schedule

       EPA has established four IDSE compliance schedules, summarized in the table in Exhibit
2.1.  If you arc a consecutive or wholesale system, your schedule is based on the population
served by the largest system in your combined distribution system. If you are not a consecutive
or wholesale system, your schedule is based on the population served by your individual system.
EPA and your state have worked together to identify which systems are part of combined
distribution systems.
IDSE Guide for Systems Serving < 10,000           2-1                               .January 2006

-------
                           Exhibit 2.1  IDSE Schedule Number
If you arc this kind of system:
Systems belonging to a combined distribution system in
which the largest system serves 100,000 people or more
Systems belonging to a combined distribution system in
which the largest system serves 50,000 to 99,999 people
Systems belonging to a combined distribution system in
which the largest system serves 10,000 to 49,999 people
Systems serving fewer than 1 0,000 people and not
connected to a system serving 1 0,000 people or more
You arc on
IDSE schedule
number
1
2
3
4
Your first
deadline is
October 1,2006
April 1,2007
October 1,2007
April 1,2008
       Every system that is subject to the Stage 2 DBPR should receive a letter from EPA or
the state with information on the Stage 2 DBPR and a determination of IDSE schedule (i.e.,
schedule 1, 2, 3, or 4). Exhibit 2.2 is an example of a letter sent by EPA to a system on schedule
1.  Letters from states and letters to systems on other schedules look similar.  Systems that EPA
or the state anticipates arc on schedules 1 and 2 should receive a letter in February 2006.
Systems that EPA or the state anticipates arc on schedules 3 and 4 should receive a letter in July
2006. States determined your schedule based on their records on your population  served and
connections to other systems. You should make sure the schedule determination in the letter is
consistent with your system size,  source water type, and buying / selling relationships with other
systems before proceeding.

       Some systems may be planning treatment changes before, during, or after the IDSE.
Most treatment plant modifications should not impact the relative formation of DBPs in your
distribution system. There arc no provisions in  the Stage 2 DBPR that allow the IDSE schedule
to  be changed or delayed1.  Not meeting the IDSE compliance deadlines in your requirements
summary sheets results in a Tier 3 monitoring and reporting violation for your system.
         The Stage 2 DBPR contains provisions that allow systems to modify their Stage 2 DBPR compliance
 monitoring plan after their IDSE has been completed.  Systems should work with their state if they believe that their
 Stage 2 compliance monitoring sites should be changed after their IDSE is completed.
 IDSE Guide for Systems Serving < 10,000
2-2
January 2006

-------
                Exhibit 2.2 Example Letter from EPA to System on Schedule 1
System Name
System Address
City State Zip
                                                                                       January 3 1 , 2006
                             * * *   Important New Rule Roll Out   * * *
                   Stage 2 Disinfectants and Disinfection Byproduct Rule (Stage 2 DBPR)
This letter applies to those systems serving 100,000 or more people OR those systems in which the largest
system in their combined distribution system serves 100,000 or more people. These systems may also be
referred to as Schedule 1 systems.
This letter is the third in a series of communications to inform you of the Stage 2 DBPR requirements. The Rule was
published in the Federal Register on January 4, 2006. The Stage 2 DBPR builds on existing regulations by requiring
water systems to meet disinfection byproduct maximum contaminant levels (MCLs) at each disinfection byproduct
monitoring site in the distribution system to better protect public health. All community water systems (CWSs) and
non-transient noncommunity water systems (NTNCWSs) that use or deliver water treated with a primary or residual
disinfectant other than ultraviolet lighl arc subject to the Stage 2 DBPR requirements. However, NTNCWS, serving
less than 10.000 people do not have to comply with the Initial Distribution System Evaluation (IDSE) requirements
(sec below for an explanation of IDSE). An electronic copy of the Stage 2 DBPR can be downloaded from EPA's
website at www.epa.eovsafcwatiT disinfect ion slauc2.

The first major requirement of the Stage 2 DBPR is for systems to conduct an IDSE. The purpose of the  IDSE is to
identify locations in the distribution system that have the highest trihalomcthanc (TTHM) and highest haloacctic acid
(HAA5) concentrations. The locations in the distribution system with the highest TTHM and highest HAA5
concentrations will be used as Stage 2 DBPR compliance monitoring sites.
   EPA and State records show that your system is required to comply with Schedule 1 IDSE requirements.
   These requirements arc based on the information that your system:

   •   Serves 100,000 or more people (or those systems those systems in which the largest system in your
      combined distribution system serves 100,000 or more people); and

   •   Provides water that has been treated with a primary or residual disinfectant other than ultraviolet
      light.

   If you believe our records are incorrect please notify us at stagc2mdbp(«'cpa.gov as soon as possible.

   By October 1, 2006, Schedule 1 systems will have to comply with IDSE requirements by submitting a
   standard monitoring plan, system specific study plan, or a 40/30 certification. Systems that qualify for a
   very small system waiver would be exempt from this IDSE requirement.
(Continued)
IDSE Guide for Systems Serving < 10, 000
                                                 2-3
                                                                                     Januarc 2006

-------
Whom should I call if I don V receive my letter?

   To identify your point of contact for the IDSE, visit EPA's website at
htip:/.;wvv\v.cpa.i:ov safewater disinfection static2. The website contains a list of
contact numbers for the IDSE by state. You can also call the EPA SDWA hotline at
1-800-426-4791 for this information.
2.3    Determining Your IDSE Option

   There are four options available to meet the requirements of the IDSE:

   •   Qualify for a Very Small System (VSS) Waiver
   •   Meet 40/30 Certification requirements
   •   Conduct a System Specific Study (SSS) using existing monitoring results or a hydraulic
       model
   •   Conduct Standard Monitoring

You can use the flowchart in Exhibit 2.3 to help you determine the right IDSE option for your
system. Example 2.1 shows how a surface water system serving 4,000 people used the
information in this chapter to determine their requirements.

   The IDSE Tool works through the flowchart to determine the most suitable
IDSE Option for your system. The tool is available on EPA's website at
http: •'/ww\v .cna.gov<'saI'ewatcrdisinCcetion stage2.
                                                                          SDSE Too!

2.4    IDSE Requirements Summary Sheets

   EPA has prepared Requirements Summary Sheets that contain key information and
compliance deadlines for each IDSE schedule and option. A list of requirements summary
sheets and their page numbers is provided in Exhibit 2.4 and in the table of contents of this
guidance manual.  EPA recommends that you make a copy of the requirements summary sheet
for your IDSE schedule and option and keep it handy throughout the IDSE process.

How does population served affect my IDSE requirements?

IDSE Schedule
•  If you are a consecutive or wholesale system, your IDSE schedule is based on the population
   served by the largest system in your combined distribution system and is designated in a
   letter from EPA or your state.

•  If you are not a consecutive or wholesale system, your IDSE schedule is based on the
   population served by your system.

IDSE Monitoring
•  For all systems, IDSE monitoring locations and sampling frequency are based on the
   population served by your individual system.
IDSE Guide for Systems Serving < 10,000           2-4                               Januaiy 2006

-------
                     Exhibit 2.3  Flowchart for Determining Your IDSE Option
                                                                    Yes
                                                            /You qualify for a very small system w aiver  You dox.
                                                            '    not have to do an DSE unless EPA or your State    \
                                                              contacts you  Go to Rage 2-9 for a summary of your   I
                                                                 Stage 2 requirements  See Chapter 3 for more     I
                                                            \^                  information                   /
                                      Do you
                                have TTHM and HAAS
                                data as required by the
                                   Stage 1 DBPR?
   Does your
system serve 500
    people or
     more?
                                 For the periods listed below1, is
                                 Every TTHM sample <. 0.040 mg/L and
                                 Every HAAS sample <. 0.030 mg/L?
                                 if you are on Schedules 1 or 2 -8 consecutive
                                 quarters starting no earlier than January 2004
                                 If you are on Schedules 3 or 4 - 8 consecutive
                                 quarters starting no earlier than January 2005
      Do you
   have TTHM and
HAAS data equivalent
to w hat is required by
    the Stage 1
      DBPR?
                                                                                        Haveyou
                                                                                   had any Stage 1
                                                                                    or HAA5 monitoring
                                                                                    violations during the
                                                                                          ity period'
                                                                         You qualify for 40/30 certification
                                                                         Go to the follow ing pages
                                                                         -Systems on Schedule 1 - Page 2-11
                                                                         -Systems on Schedule 2 - Page 2-13
                                                                         -Systems on Schedule 3 - Page 2-15
                                                                         -Systems on Schedule 4 - Page 2-17
                                                                         See Chapter 4 for more information on
                                                                         the 40/30 certification
                                  Do you have extensive
                                  TTHM and HAAS data
                                   (compliance and/or
                                      operational)9
have a distribution
 You may be able to perform a System
Specific Study  See the IDSE Guidance
       Manual for more details
                                            You are required to conduct standard
                                            monitoring  Go to the follow ing pages:
                                            -Systems on Schedule 1 - Page 2-19
                                            -Systems on Schedule 2 - Page 2-21
                                            -Systems on Schedule 3 - Rage 2-23
                                            -Systems on Schedule 4 - Page 2-25
                                            See Chapter 5 for more information on
                                           .standard monitoring.
1Unless you are on reduced monitoring for Stage 1 and w ere not required to monitor during the specified period.  If you did not
monitor during the specified period, you must base your eligibility on compliance samples taken during the 12 months preceding the
specified period
  IDSE Guide for Systems Sen-ing < 10.000
                                                                                                    Januarv 2006

-------
 Example 2.1  Determining IDSE Requirements for a Consecutive System Serving
                                   4,000 People

System X is a consecutive system serving 4,000 people.  They purchase all of their water from
System Y, which is a wholesale surface water system that serves their own retail population of
 10,000 people. System X received a letter from their state notifying them of the new Stage 2
DBPR and stating that they are on Schedule 1. System X called System Y right away to
confirm that they were on the same schedule.

Next, System X began working through the flowchart in Exhibit 2.3 of the IDSE Guide for
Systems Serving < 10,000 to determine their IDSE option.

       •      They serve more than 500 people and cannot qualify for the VSS waiver.

             Their Stage 1  DBPR monitoring results for TTHM were between 45 and 70
             micrograms per liter (ng/L), so they did not qualify for the 40/30 certification.

       •      System X docs not have a hydraulic model or extensive existing TTHM an
             HAAS data. Therefore System  X was required to perform Standard
             Monitoring.

To determine which chapters of the IDSE manual they needed, System X referred to Exhibit
 .2.  System X then downloaded Chapters  1, 2, and 5 and Appendices A and B  of the IDSE
Guide for Systems Serving < 10,000 People from
hltp:' w\v\\.cpa.izov;sai'cvvalcrdisinfcc'lion stagc2 to build their own custom manual.  They
made a copy of the requirements summary sheet titled "Standard Monitoring - Schedule 1" to
keep handy throughout the IDSE process.  They began preparing their IDSE
Standard Monitoring Plan.
Note: If System X had used the IDSE tool, it would have done these steps for      IDSE jool
them and created a custom form for their IDSE Standard Monitoring Plan.
IDSE Guide for Systems Sewing < 10,000          2-6                               January 2006

-------
                Exhibit 2.4 List of Requirements Summary Sheets
Requirement Summary Sheet
Requirements for Very Small System Waivers
40/30 Certification Requirements - Schedule 1
40/30 Certification Requirements - Schedule 2
40/30 Certification Requirements - Schedule 3
40/30 Certification Requirements - Schedule 4
Standard Monitoring Requirements - Schedule 1
Standard Monitoring Requirements - Schedule 2
Standard Monitoring Requirements - Schedule 3
Standard Monitoring Requirements - Schedule 4
Standard Monitoring Requirements - Attachment (For All Schedules)
Page
2-9
2-11
2-13
2-15
2-17
2-19
2-21
2-23
2-25
2-27
IDSE Guide for Systems Sewing < 10,000
2-7
Jamtarv 2006

-------
                               This page left intentionally blank.
IDSE Guide for Systems Sewing < 10,000            2-8                                   Januaiy 2006

-------
I   Requirements for Very Small System Waivers        page i of 2
                                                                                 II

 This summary sheet is for systems that:
    •   Serve fewer than 500 people, and
    •   Have taken TTHM and HAAS samples.

 WHAT TO DO NOW:
 You have NO further requirements for the IDSE unless EPA or your state contacts you.  If EPA
 or your state contacts you, they will work with you to determine an appropriate IDSE schedule
 for your system. See Chapter 3 for more information.

 Continue compliance monitoring for the Stage 1 DBPR until you begin compliance monitoring
 for the Stage 2 DBPR

 NEXT STEPS:
 You must start taking Stage 2 DBPR compliance monitoring samples by the deadline listed on
 the next page. You must prepare a Stage 2 compliance monitoring plan before you take your
 first compliance sample.

 If you have high levels of DBFs, you may need to make system changes to meet the
 requirements of the Stage 2 DBPR.  Sec Chapter 1, Section 1.1  of this guidance manual, for a
 list of additional guidance materials for the Stage 2 DBPR.  If you buy water from another public
 water system, see EPA's Consecutive System Guidance Manual for more information.

 Reminder:
 Your requirements for Stage 2 DBPR compliance monitoring (locations and frequency) are
 based on the population served by your system and are listed on the next page.
IDSE Guide for Systems Sci-ving < 10.000 '         2-9                              January 2006

-------
  Requirements for Very Small System Waivers
                                   Page 2 of 2
                Stage 2 DBPR Compliance Monitoring Deadlines
Schedule (population served)1
Schedule 1 (> 100,000)
Schedule 2 (50,000 - 99,999)
Schedule 3 (10,000 -49,999)
Schedule 4 (< 10,000)
Year in Which You Must Begin Stage 2
Compliance Monitoring
2012
2012
2013
2013or20142
1 If you are a consecutive or wholesale system, your schedule is based on the largest system in your
combined distribution system. You should have received a letter from EPA or your state with your
schedule for the Stage 2 DBPR.
22014 if Cryptosporidium monitoring is required under 141.701(a)(4) or (a)(6).
Sta
Source Water
Type
Subpart H
Ground Water
ge 2 DBPR Compliance Monitoring Req
Population Size
Category1
<500
<500
Monitoring
Frequency2
per year
per year
uirenients
Distribution System
Monitoring Location1
2
2
1 Your monitoring requirements (location and frequency) are based on the population served by your
individual system.
2 You must monitor during the month of highest DBP concentrations.
3 You are required to take individual TTHM and HAAS samples at the locations with the highest TTHM and
HAAS concentrations, respectively. Only one location with a dual sample set per monitoring period is
needed if the highest TTHM and HAAS concentrations occur at the same location and month.
IDSE Guidejor Systems Serving < 10,000
2-10
January 2006

-------
  40/30 Certification Requirements - Schedule  1         pagc i Of 2
                                                                    Submit 40/30
                                                                   Certification by
                                                                     Oct. 1,2006
 Jan. 1,2004            Collect 40/30 Data for Any 8 Consecutive
                              Quarter EligibilityPeriod
                2004
2005
2006
                                                Rule Promulgation
This summary sheet is for systems that satisfy all of the following requirements for any 8
consecutive quarter eligibility period beginning no earlier than January 2004:
    •   You are part of a combined distribution system where the largest system serves 100,000
       people or more
       You have TTHM and HAA5 data equivalent to what is required by the Stage 1 DBPR
       No individual sample exceeds 0.040 mg/L for TTHM
    •   No individual sample exceeds 0.030 mg/L for HAAS
    •   Your system did not have any TTHM  or HAAS monitoring violations

WHAT TO DO NOW:
1.  Prepare a certification letter                            f   Due: October 1, 2006
You must submit the certification letter to the address or e-mail provided below, or use the IDSE
Tool to prepare and submit your certification letter. Note that EPA or your state could contact
you and require more information, or require you to conduct an IDSE.

For more information and letter templates:
See Chapter 4 of this guidance manual.  If you arc a consecutive or wholesale
system, see Appendix A of this guidance manual. A template you can use for your
40/30 certification letter is included on Page 4-4. If you would like an electronic
template, use the IDSE Tool, available at                                       I05E j00;
http:/.'www.cna.«j:ov/.safc\\'ater/disinl'eciion/'stage2.

2. Mail your 40/30 certification letter to:
   STAGE 2 DBPR
   US EPA-IPMC
   P O Box 98
   Dayton, OH  45401-0098

Email to stagc2mdbp(«.cpa.gov or submit electronically via the IDSE tool
IDSE Guide for Systems Sewing < 10,000          2-11                               January- 2006

-------
  40/30 Certification Requirements - Schedule 1
                                   Page 2 of 2
3. Continue compliance monitoring for the Stage
monitoring for the Stage 2 DBPR.
      DBPR until you begin compliance
NEXT STEPS:
You have additional Stage 2 DBPR requirements. You must:
       •   Select Stage 2 DBPR compliance monitoring sites
       •   Develop a Stage 2 compliance monitoring plan before you take your first compliance
          sample.  If you are a subpart H system and you serve more than 3,300 people, you
          need to submit your plan to the state.
       •   Begin annual or quarterly Stage 2 compliance monitoring during the period starting
          with April 2012, according to your Stage 2 compliance monitoring plan

See Chapter 1, Section 1.1 of this guidance manual for a list of additional guidance materials
for the Stage 2 DBPR.

Reminder:
Your requirements for Stage 2 compliance monitoring arc based on the population of your
system and arc listed below

              Stage 2 DBPR Compliance Monitoring Requirements
Source Water
Type
Subpart H
Ground
Water
Population Size
Category1
•500
500-3,300
3,301-9,999
<500
500-9.999
Monitoring
Frequency2
per year
per quarter
per quarter
per year
per year
Distribution System Monitoring Location
Total per
monitoring
period'
2
2
2
2
2
Highest TTHM
Locations
1
1
1
1
1
Highest HAAS
Locations
1
1
1
1
1
1 Your monitoring requirements (location and frequency) are based on the population served by your system.
2 All systems must monitor during month of highest DBF concentrations.
3 Systems on quarterly monitoring must take dual sample sets every 90 days at each monitoring location, except for
subpart H systems serving 500-3,300. Systems on annual monitoring and subpart H systems serving 500-3,300 are
required to take individual TTHM and HAAS samples (instead of a dual sample set) at the locations with the highest
TTHM and HAAS concentrations, respectively. Only one location with a dual sample set per monitoring period is
needed if highest TTHM and HAAS concentrations occur at the same location (and month, if monitored annually).
IDSE Guide for Systems Serving < 10.000
2-12
January 2006

-------
       40/30 Certification Requirements - Schedule 2          pagc i of 2
                                                                     Submit 40/30
                                                                    Certification by
                                                                     ApriM,2007
Jan. 1,2004                      Collect 40/30 Data for Any 8 Consecutive
Uuarter bligiDiiityKerioa
i
2004
2005 1 2006
r
2007
                                         Rule Promulgation
     This summary sheet is for systems that satisfy all of the following requirements for any 8
     consecutive quarter eligibility period beginning no earlier than January 2004:
         •   You arc part of a combined distribution system where the largest system serves 50,000-
            99,999 people
         •   You have TTHM and HAAS data equivalent to what is required by the Stage 1 DBPR
         •   No individual sample exceeds 0.040 mg/L for TTHM
            No individual sample exceeds 0.030 mg/L for HAAS
         •   Your system did not have any TTHM or HAAS monitoring violations

     WHAT TO DO NOW:
     1.  Prepare a certification letter                           |	Due: April 1,2007
     You must submit the certification letter to the address or e-mail provided below, or use the IDSE
     Tool to prepare and submit your certification letter. Note that EPA or your state could contact
     you and require more information, or require you to conduct an IDSE.

     For more information and letter templates:
     See Chapter 4 of this guidance manual. If you are a consecutive or wholesale system, see
     Appendix A of this guidance manual. A template you can use for your 40/30
     certification letter is included on Page 4-4. If you would like an electronic
     template, use the IDSE Tool, available  at
     http://wwvv.cpa.gov/salcwatcpdisinfoction/stage2.                               ID5E Too[

     2. Mail your 40/30 certification letter to:
        STAGE 2 DBPR
        US EPA-IPMC
        P O Box 98
        Dayton, OH  45401-0098

     Email to stage2mdbpfa.,epa.gov or submit electronically via the IDSE tool
     IDSE Guide for Systems Serving < 10,000          2-13                               January 2006

-------
  40/30  Certification Requirements - Schedule 2
                                    Page 2 of 2
3. Continue compliance monitoring for the Stage 1 DBPR until you begin compliance
monitoring for the Stage 2 DBPR.

NEXT STEPS:
You have additional Stage 2 DBPR requirements. You must:
    •   Select Stage 2 compliance monitoring sites
    •   Develop a Stage 2 compliance monitoring plan before you take your first compliance
       sample.  If you are a subpart H system and you serve more than 3,300 people, you need
       to submit your plan to the state.
    •   Begin annual or quarterly Stage 2 compliance monitoring during the period starting with
       October 2012, according to your Stage 2 compliance monitoring plan.

Sec Chapter 1, Section 1.1 of this guidance manual for a list of additional guidance materials
for the Stage 2 DBPR.

Reminder:
Your requirements  for Stage 2 compliance monitoring arc based on the population of your
system and arc listed below.

              Stage 2 DBPR Compliance Monitoring Requirements
Source
Water Type
Subpart
H
Ground
Water
Population Size
Category1
<500
500-3,300
3,301-9.999
<500
500-9.999
Monitoring
Frequency2
per year
per quarter
per quarter
per year
per year
Distribution System Monitoring Location
Total per
monitoring
period1
2
2
2
2
2
Highest TTHM
Locations
1
1
1
1
1
Highest HAAS
Locations
1
1
1
1
1
'  Your monitoring requirements (location and frequency) are based on the population served by your system.
2 All systems must monitor during month of highest DBF concentrations.
3 Systems on quarterly monitoring must take dual sample sets every 90 days at each monitoring location, except for
subpart H systems serving 500-3,300. Systems on annual monitoring and subpart H systems serving 500-3,300 are
required to take individual TTHM and HAAS samples (instead of a dual sample set) at the locations with the highest
TTHM and HAAS concentrations, respectively. Only one location with a dual sample set per monitoring period is
needed if highest TTHM and HAAS concentrations occur at the same location (and month, if monitored annually).
IDSE Guide for Systems Serving < 10,000
2-14
January 2006

-------
  40/30 Certification Requirements - Schedule 3         Page i of2
                                                                      Submit 40/30
                                                                     Certification by
                                                                       Oct. 1,2007
 Jan. 1,2005            Collect 40/30 Data for Any 8 Consecutive
                              Quarter EligibilityPeriod
     w	
                2005
2006
2007
                       Rule Promulgation

This summary sheet is for systems that satisfy all of the following requirements for any 8
consecutive quarter eligibility period beginning no earlier than January 2005:
    •   You arc part of a combined distribution system where the largest system serves  10,000-
       49,999 people
    •   You have TTHM and HAA5 data equivalent to what is required by the Stage 1 DBPR
    •   No individual sample exceeds 0.040 mg/L for TTHM
    •   No individual sample exceeds 0.030 mg/L for HAA5
    •   Your system did not have any TTHM or HAA5 monitoring violations

WHAT TO DO NOW:
1. Prepare a certification letter                            [    Due; October 1,2007   |
You must submit the certification  letter to the address or e-mail provided below, or use  the IDSE
Tool to prepare and submit your certification letter. Note that EPA or your state could contact
you and require more information, or require you to conduct an IDSE.

For more information and letter templates:
See Chapter 4 of this guidance manual. If you are a consecutive or wholesale
system, see Appendix A of this guidance manual. A template you can use for your
40/30 certification letter is included on Page 4-4. If you would like an electronic
template, use the IDSE Tool, available at                                       IDSE To°l
hrtp://ww\v.epa.gov/safcwater'disinfcction/stauc2.

2. Mail your 40/30 certification  letter to:
   STAGE 2 DBPR
   US EPA-IPMC
   P O Box 98
   Dayton, OH  45401-0098

Email to stagc2mdbp(q ;cpa. goy or submit electronically via the  IDSE tool
IDSE Guide for Systems Serving < 10,000          2-15                              January 2006

-------
  40/30  Certification Requirements - Schedule 3
                                   Page 2 of2
3. Continue compliance monitoring for the Stage 1 DBPR until you begin compliance
monitoring for the Stage 2 DBPR.

NEXT STEPS:
You have additional Stage 2 DBPR requirements.  You must:
    •   Select Stage 2 compliance monitoring sites
    •   Develop a Stage 2 compliance monitoring plan before you take your first compliance
       sample. If you are a subpart H system and you serve more than 3,300 people, you need to
       submit your plan to the state.
       Begin annual or quarterly Stage 2 compliance monitoring during the period starting with
       October 2013, according to your Stage 2 compliance monitoring plan

See Chapter 1, Section 1.1 of this guidance manual for a list of additional guidance materials for
the Stage 2 DBPR.
Reminder:
Your requirements  for Stage 2 compliance monitoring arc based on the population of your system
and arc listed below
               Stage 2 DBPR Compliance Monitoring Requirements
Source Water
Type
Subpart
H
Ground
Water
Population Size
Category1
•-500
500-3.300
3,301-9,999
<500
500-9,999
Monitoring
Frequency2
per year
per quarter
per quarter
per year
per year
Distribution System Monitoring Location
Total per
monitoring
period5
t
**
2
2
2
1
Highest TTHM
Locations
!
1
1
1
1
Highest HAAS
Locations
1
1
1
1
1
1 Your monitoring requirements (localion and frequency) are based on the population served by your system.
2 All systems must monitor during month of highest DBF concentrations.
3 Systems on quarterly monitoring must take dual sample sets every 90 days at each monitoring location, except for
subpart H systems serving 500-3,300.  Systems on annual monitoring and subpart H systems serving 500-3,300 are
required to take individual TTHM and HAAS samples (instead of a dual sample set) at the locations with the highest
TTHM and HAAS concentrations, respectively.  Only one location with a dual sample set per monitoring period is
needed if highest TTHM and HAAS concentrations occur at the same location (and month, if monitored annually).
IDSE Guide jor Systems Serving < 10,000
2-16
January 2006

-------
        40/30 Certification Requirements - Schedule 4          pagc i of 2
                                                                         Submit 40/30
                                                                        Certification by
                                                                         April 1.2008
Jan. 1,2005                Collect 40/30 Data for Any 8 Consecutive
Quarter Eligibility Period
>
2005
2006
2007
r
2008
                   Rule Promulgation

      This summary sheet is for systems that satisfy all of the following requirements for any 8
      consecutive quarter eligibility period beginning no earlier than January 2005:
         •   You serve fewer than 10,000 people OR arc part of a combined distribution system where
            the largest system serves fewer than 10,000 people
         •   You have TTHM and HAAS data equivalent to what is required by the Stage 1  DBPR
         •   No individual sample exceeds 0.040 mg/L for TTHM
         •   No individual sample exceeds 0.030 mg/L for HAAS
         •   Your system did not have any TTHM or HAAS monitoring violations

      WHAT TO DO NOW:
      1. Prepare a certification letter                           	Due: April 1, 2008
      You must submit the certification letter to the address or e-mail provided below, or use the IDSE
      Tool to prepare and submit your certification letter. Note that EPA or your state could contact
      you and require more information, or require you to conduct an IDSE.

      For more information and letter templates:
      See Chapter 4 of this guidance manual. If you are a consecutive or wholesale
      system, see Appendix A of this guidance manual. A template you can use for your
      40/30 certification letter is included on Page 4-4. If you would like an electronic
      template, use the IDSE Tool, available at                                       IDSE Tool
      http:'' www.epa.gov/safbwatciAiisintcction/stagc2.

      2. Mail your 40/30 certification letter  to:
         STAGE 2 DBPR
         US EPA-IPMC
         P O Box 98
         Dayton, OH 45401-0098

      Email to stagc2mdbpfecpa.gov or submit electronically via the IDSE  tool
     IDSE Guide for Systems Serving < 10,000           2-17                              January 2006

-------
     40/30 Certification Requirements - Schedule 4
                                   Page 2 of 2
   3. Continue compliance monitoring for the Stage 1 DBPR until you begin compliance
   monitoring for the Stage 2 DBPR.

   NEXT STEPS:
   You have additional Stage 2 DBPR requirements. You must:
       •   Select Stage 2 compliance monitoring sites
       •   Develop a Stage 2 compliance monitoring plan before you take your first compliance
          sample.  If you are a subpart H system and you serve more than 3,300 people, you need
          to submit your plan to the state.
       •   Begin annual or quarterly Stage 2 compliance monitoring during the period starting with
          October 2013 or October 2014, according to your Stage 2 compliance monitoring plan.

   See Chapter 1, Section 1.1 of this guidance manual for a list of additional guidance materials
   for the Stage 2 DBPR.
   Reminder:
   Your requirements for Stage 2 compliance monitoring arc based on the population of your
   system and arc listed below.
                     Stage 2 DBPR Compliance Monitoring Requirements
Source
Water Type
Subpart
H
Ground
Water
Population Size
Category1
<500
500-3,300
3,301-9,999
<500
500-9,999
Monitoring
Frequency2
per year
per quarter
per quarter
per year
per year
Distribution System Monitoring Location
Total per
monitoring
period3
2
2
2
2
2
Highest TTHM
Locations
1
1
1
1
1
Highest HAA5
Locations
1
1
1
1
1
   1  Your monitoring requirements (location and frequency) are based on the population served by your system.
   2 All systems must monitor during month of highest DBF concentrations.
   3 Systems on quarterly monitoring must take dual sample sets every 90 days at each monitoring location, except for
   subpart H systems serving 500-3,300.  Systems on annual monitoring and subpart H systems serving 500-3,300 are
   required to take individual TTHM and HAA5 samples (instead of a dual sample set) at the locations with the highest
   TTHM and HAAS concentrations, respectively. Only one location with a dual sample set per monitoring period is
   needed if highest TTHM and HAA5 concentrations occur at the same location (and month, if monitored annually).
IDSE Guide for Systems Sewing < 10,000
2-18
January 2006.

-------
  Standard Monitoring Requirements - Schedule 1     pagc
                                     1 of 2
       Submit Standard
       Monitoring  Plan
        by Oct. 1,2006
                Submit IDSE
                 Report by
                Jan. 1,2009
^
Oct. 1,
i
2007 Sept. 30
Conduct Standard
Monitoring
(recommended)
,2008
^
2006 | 2007 2008
r
2009
Rule Promulgation
This summary sheet is for systems that serve 100,000 people or more OR arc part of a combined
distribution system where the largest system serves 100,000 people or more.
WHAT TO DO NOW:
1. Develop Standard Monitoring Plan
                    Due: October 1, 2006
   •   Sec Chapter 5, Section 5.1.3 for guidance on how to develop your IDSE Standard
       Monitoring Plan. Your monitoring requirements arc also listed on the attachment on
       Pagc 2-27.
   •   Chapter 5 contains plan templates. If you would like an electronic template, sec the
       IDSE Tool: http://www.epa.gov salcvvatcr/'disinfcction/slaucZ.

Mail your standard monitoring plan to:

   STAGE 2 DBPR                                                       ID$E Tool
   US EPA-IPMC
   P O Box 98
   Dayton, OH 45401-0098

E-mail to stagc2mdbpu/-cpa.gov or submit electronically via the IDSE tool

EPA or your state will review your standard monitoring plan and contact you before
October 1, 2007 to either let you know it has been approved or discuss necessary changes. If
you do not hear anything by this deadline, consider your plan approved and start monitoring.
2. Conduct Standard Monitoring
                 Oct. 1,2007-Sept. 30, 2008
Monitoring should be done according to your standard monitoring plan.
IDSE Guide lor Systems Serving < 10.000
2-19
Januan' 2006

-------
 Standard Monitoring Requirements - Schedule 1      pagc 2 of 2
                                                           Due: January 1, 2009
WHAT TO DO NOW (cont'd):
3.  Select Stage 2 Compliance Monitoring Sites and Develop
IDSE Standard Monitoring Report
   •   See Chapter 5, Section 5.3 for guidance on how to select Stage 2 compliance monitoring
       sites and write the IDSE report. The number of Stage 2 compliance monitoring sites
       required for your system is listed on the attachment on Page 2-28.
   •   EPA or your state will review your IDSE report and contact you before April 1,
       2009 to either let you know your Stage 2 compliance monitoring sites and schedule have
       been approved or to discuss necessary changes. If you do not hear anything by this
       deadline, consider your plan approved and start preparing for Stage 2 compliance.

4.  Continue compliance monitoring for the Stage 1 DBPR until you begin compliance
monitoring for the Stage 2 DBPR.

NEXT STEPS:
You will have additional requirements for Stage 2 compliance. Your system will need to do the
following:
   •   If you have high levels of DBPs, you may need to make system changes before April 1,
       2012 to meet the Stage 2 MCLs.  If you buy water, sec the Consecutive System Guidance
       Manual for more information.
   •   Develop a Stage 2 compliance monitoring plan before you take your first compliance
       sample. If you arc a subpart H system and you serve more than 3,300 people, you need
       to submit your plan to the state.
   •   Begin annual or quarterly Stage 2 compliance monitoring during the period starting with
       April 2012, according to your Stage 2 compliance monitoring plan.

Reminder:
Your system's monitoring requirements for both the IDSE and Stage 2 compliance monitoring
are based on the population of your system and are listed in the attachment on Pages 2-27 and 2-
28.
IDSE Guide for Systems Serving < 10,000         2-20                             January 2006

-------
   Standard Monitoring Requirements - Schedule 2     page i of 2
                   Submit Standard
                   Monitoring Plan
                   by April 1,2007
                                                                  Submit IDSE
                                                                   Report by
                                                                  July 1,2009
>
April 1
r
, 2008 March 31
-* »-
Conduct Standard
Monitoring
(recommended)
,2009
>
r
2006 | 2007 2008 | 2009
Rule Promulgation

  This summary sheet is for systems that serve 50,000-99,999 people OR arc part of a combined
  distribution system where the largest system serves 50,000-99,999 people.
WHAT TO DO NOW:
1.  Develop Standard Monitoring Plan
                                                             Due: April 1,2007
        Sec Chapter 5, Section 5.1.3 for guidance on how to develop your IDSE Standard
        Monitoring Plan. Your monitoring requirements arc also listed on the attachment on
        Page 2-27.
        Chapter 5 contains plan templates.  If you would like an electronic
        template, sec the IDSE Tool:
        blip: 'www.epa.jiov safcwatcrdisinlcclion stanc2.
  Mail your standard monitoring plan to:

     STAGE 2 DBPR
     US EPA-IPMC
     P O Box 98
     Dayton, OH  45401-0098

  E-mail to stagc2rndbp/». cpa.gov or submit electronically via the IDSE tool

  EPA or your state will review your standard monitoring plan and contact you before April
  1, 2008 to either let you know it has been approved or discuss necessary changes. If you do not
  hear anything by this deadline, consider your plan approved and start monitoring.
 2. Conduct Standard Monitoring                         [Apr. 1, 2008 - March 31, 2009
 Monitoring should be done according to your standard monitoring plan.
 IDSE Guide for Systems Serving < 10.000
                                       2-21
Januarv 2006

-------
  Standard Monitoring Requirements - Schedule 2     pagc 2 of2
WHAT TO DO NOW (cont'd):
3. Select Stage 2 Compliance Monitoring Sites and Develop
IDSE Standard Monitoring Report                                     y '
   •   See Chapter 5, Section 5.3 for guidance on how to select Stage 2 compliance monitoring
       sites and write the IDSE report. The number of Stage 2 compliance monitoring sites
       required for your system is listed on the attachment on Page 2-28.
   •   EPA or your state will review your IDSE report and contact you before October 1,
       2009 to either let you know your Stage 2 compliance monitoring sites and schedule have
       been approved or to discuss necessary changes. If you do not hear anything by this
       deadline, consider your plan approved and start preparing for Stage 2 compliance.

4. Continue compliance monitoring for the Stage 1 DBPR until you begin compliance
monitoring for the Stage 2 DBPR.

NEXT STEPS:
You will have additional requirements for Stage 2 compliance. Your system will need to do the
following:
   •   If you have high levels of DBPs, you may need to make system changes before October
       1, 2012 to meet the Stage 2 MCLs.  If you buy water, see the Consecutive System
       Guidance Manual for more information.
   •   Develop a Stage 2 compliance monitoring plan before you take your first compliance
       sample. If you arc a subpart H system and you serve more than 3,300 people, you need
       to submit your plan to the state.
   •   Begin annual or quarterly Stage 2 compliance monitoring during the period starting with
       October 2012, according to your Stage 2 compliance monitoring plan.

Reminder:
Your system's monitoring requirements for both the IDSE and Stage 2 compliance monitoring
arc based on the population of your system and are listed in the attachment on Pages 2-27 and 2-
28
IDSE Guide jor Systems Serving < 10,000          2-22                              January 2006

-------

Standard Monitoring Requirements - Schedule 3 pagc i of 2
Submit £
Monitori
by Oct.
i
Standard
ng Plan
1,2007
Oct. 1
2006 | 2007 | 2008
Submi
Repc
Jan. 1
, 2008 Sept. 30, 2009
Conduct Standard
Monitoring
(recommended)
| 2009
^

tIDSE
>rt by
,2010
r
2010
Rule  Promulgation
       This summary sheet is for systems that serve 10,000-49,999 people OR arc part of a combined
       distribution system where the largest system serves 10,000-49,999 people.
       WHAT TO DO NOW:
       1.  Develop Standard Monitoring Plan
                      Due: October 1,2007
          •  Sec Chapter 5, Section 5.1.3 for guidance on how to develop your IDSE Standard
             Monitoring Plan. Your monitoring requirements arc also listed on the attachment on Pagc
             2-27.
          •  Chapter 5 contains plan templates.  If you would like an electronic template, sec the 1DSE
             Tool: Iutp:/.'ww\v.cpa.uo\'/safewater/disml'ection/stauc2

       Mail your standard monitoring plan to:

          STAGE 2 DBPR
          US EPA-IPMC
          P O Box 98
          Dayton, OH  45401-0098

       E-mail to stagc2mdbp(a/.epa.gov or submit electronically via the IDSE tool

       EPA or your state will review your standard monitoring plan and contact you before
       October 1, 2008 to either let you know it has been approved or discuss necessary changes. If you
       do not hear anything by this deadline, consider your plan approved and start monitoring.
       2. Conduct Standard Monitoring                          |  Oct. 1, 2008 - Sept. 30, 2009
       Monitoring should be done according to your IDSE Standard Monitoring Plan.
      IDSE Guide Jor Systems Sci-ving < 10,000
2-23
Jam/an' 2006

-------
 Standard Monitoring Requirements - Schedule 3      pagc 2 of 2
                                                            Due: January 1, 2010
WHAT TO DO NOW (cont'd):
3. Select Stage 2 Compliance Monitoring Sites and Develop
IDSE Standard Monitoring Report                        	
   •   See Chapter 5, Section 5.3 for guidance on how to select Stage 2 compliance monitoring
       sites and write the IDSE report. The number of Stage 2 compliance monitoring sites
       required for your system is listed on the attachment on Page 2-28.
   •   EPA or your state will review your IDSE report and contact you before October 1,
       2010 to either let you know your Stage 2 compliance monitoring sites and schedule have
       been approved or to discuss necessary changes. If you do not hear anything by this
       deadline, consider your plan approved and start preparing for Stage 2 compliance.

4. Continue compliance monitoring for the Stage 1 DBPR until you begin compliance
monitoring for the Stage 2 DBPR.

NEXT STEPS:
You will have additional requirements for Stage 2 compliance. Your system will need to do the
following:
   •   If you have high levels ofDBPs, you may need to make system changes before October
       1, 2013 to meet the Stage 2 MCLs.  If you buy water, sec the Consecutive System
       Guidance Manual for more information.
   •   Develop a Stage 2 compliance monitoring plan before you take your first compliance
       sample. If you are a  subpart H system and you serve more than 3,300 people, you need to
       submit your plan to the slate.
   •   Begin annual or quarterly Stage 2 compliance monitoring during the period starting with
       October 2013, according to your Stage 2 compliance monitoring plan.

Reminder:
Your system's monitoring requirements for both the IDSE and Stage 2 compliance monitoring are
based on the population of your system and are listed in the attachment on Pages 2-27 and 2-28.
IDSE Guide for Systems Serving < 10,000          2-24                              Januaiy 2006

-------
Standard Monitoring Requirements - Schedule 4 pagc i or 2
Submit £
Monitori
by April
i
Standard
ng Plan
1,2008
April
2006 2007 2008
Submi
Repc
July 1
1,2009 March 31, 2010
Conduct Standard
Monitoring
(recommended)
2009 |
T
tIDSE
tit by
,2010
2010
Rule Promulgation
      This summary sheet is for systems that serve fewer than 10,000 people OR are part of a combined
      distribution system where the largest system serves fewer than 10,000 people.

      W H AT TO DO N OW:
      1.  Develop Standard Monitoring Plan                       |     Due: April 1,2008      |
         •   Sec Chapter 5, Section 5.1.3 for guidance on how to develop your 1DSE Standard
             Monitoring Plan. Your monitoring requirements arc also listed on the attachment on Pagc
             2-27.
         •   Chapter 5 contains plan templates.  If you would like an electronic
             template, sec the IDSE Tool:
             !ntp:J''wwu.L'pa.gov'sal'e\vatcr/disin('cctioivstagc2.
                                                                                  1DSE Tool
      Mail your standard monitoring plan to:

         STAGE 2 DBPR
         US EPA-IPMC
         P O Box 98
         Dayton, OH  45401-0098

      E-mail to stagc2mdbpw, cpa.gov or submit electronically via the IDSE tool

      EPA or your state will review your standard monitoring plan  and contact you before April
      1, 2009 to either let you know it has been approved or discuss necessary changes.  If you do not
      hear anything by this deadline, consider your plan approved and start monitoring.
      2. Conduct Standard Monitoring                           [Apr. 1, 2009 - March 31, 2010
      Monitoring should be done according to your standard monitoring plan.
      IDSE Guide for Systems Serving < 10,000
2-25
Januan2006

-------
  Standard Monitoring Requirements - Schedule 4      pagc2of?
WHAT TO DO NOW (cont'd):
3. Select Stage 2 Compliance Monitoring Sites and Develop        n   , .
IDSE Standard Monitoring Report                              UUe: JUly *'
   •  See Chapter 5, Section 5.3 for guidance on how to select Stage 2 compliance monitoring
      sites and write the IDSE report. The number of Stage 2 compliance monitoring sites
      required for your system is listed on the attachment on Page 2-28.
   •  EPA or your state will review your IDSE report and contact you before October 1,
      2010 to cither let you know your Stage 2 compliance monitoring sites and schedule have
      been approved or to discuss necessary changes. If you do not hear anything by this
      deadline, consider your plan approved and start preparing for Stage 2 compliance.

4. Continue compliance monitoring for the Stage 1 DBPR until you begin compliance
monitoring for the Stage 2 DBPR.

NEXT STEPS:
You will have additional requirements for Stage 2 compliance. Your system will need to do the
following:
   •  If you have high levels of DBPs, you may need to make system changes before October
      1, 2013 to meet the Stage 2 MCLs. If you buy water, sec the Consecutive System
      Guidance Manual for more information.
   •  Develop a Stage 2 compliance monitoring plan before you take your first compliance
      sample.  If you are a subpart H system and you serve more than 3,300 people, you need to
      submit your plan to the state.
   •  Begin annual or quarterly Stage 2 compliance monitoring during the period starting with
      October 2013 or October 2014, according to your Stage 2 compliance monitoring plan.

Reminder:
Your system's monitoring requirements for both the IDSE and Stage 2 compliance monitoring are
based on the population of your system and are listed in the attachment on Pages 2-27 and 2-28.
IDSE Guide for Systems Serving < 10,000         2-26                              January 2006

-------
  u
  SI)
—
"3
^
 o
-«-*
 e
 i
 =
 o>
 o>

 &JD
.S
 O
*j
*s
 o
§
T5
             e
             a>
             a-
             DJD
             e

             o
            •M
            "S
             o
            •o
             w
            •o
             B
            C/3
            Q





SB
C
e
•c
«
e
M
S
'C
S

'S
5

1
•M
V
'
»^»
C/5
B
0
*e w
ex o
£ J
M
Ijjij»-
K{jS
S
t^ v*m
fr~ w
SJS
a


o
ft* S
at) MM M.
y *M %
l-e.S
S» '5 p


*


j^.
W*
^•i ^,
W .£
k. 0
A (rt»

Z

, we
S )S
CM *r" *^
•a s-S
o'g S
*


. ««a
i ^«
8 C1 B
3 S^
s a £
: g1 §
^ t ^
• fc,


^
i
it
it
is
•
t V
^ cu











T— 1

















. )








(N



>^>
«
a.
_c
'O
c
o

<500 consecutive
systems



__








*— ^


























(N



^-^
^
O
g
"S
o
2
c/)
' ™
~
<500 non-consecutive
systems
^
i
.
J










1— H

















t 	 (








rj




c

x
<,


500-3,300 consecutive
systems
•4
•
T!
3
rj

_,








*-"*


























fN




r>
^
>^ ^^
3 in
L> C3
-^ "O
2


500-3,300 non-
consecutive systems



_*








(N







^ _.__(


















^










Os
O












*«PH

















| 	 ,








(N



*j>
W
n.
OX)
.S
3
3

0 88
a^

_








T—


























fN




O
OS
d) 1«
> >
a> 03
1


Os
Os
ON
Os"
O
0













T3
'C
p .
00

^;
^
E
O CJ
E S
.c 'TO
o *--
e o o
Sue.
£ oo S
VD C— ^
V3 E t.
•" -a u
0 C |

-o1 ™ S
"^ CJ r-1
T3 0 §
a> • — ' >-
> oo J°
% '= 0
c S •£
.2 c •-
*- o ^
-5 p i/i
&"5 5
tu ^
§ a> ^
•a ca t-
4> *" O
ca ^ "^
5. £ (-
se-l
|l*
^*— ' *^ -^
"?^^
iring requirements (locations ai
ile set (i.e.. a TTHM and an H/
itorical month is the month wit
o ti. .X;
C rn .j
2 » IS
c •= i>
S| u
^ < f5

-------

C/2
















e
^*
§
o

e
Monitor!
E
*s
g*
j-jT'
e
1
V*
w
5








b
JS
c
•M
C
1













ource
Cft



ir>
«S -
< B
* *B
tE ea
e
g""1



tTTHM
ations
V, u
«> e
•C T
B£, p-J
.Sr
IE

UJO
.9
e
•^•4
o ^
E -2
U SJ

CS
4^
e
H


Frequency2




s^»
s,
I
u

.2
on
Population

t •»
•S P"
"*"




























e3
W











O
O
v1






















(N








(U
•c
03
cr











0
o
o
o
S
a.
3
t/3




























per Quarter











ON
Os
ON
ON"
1
O
rn
m'






















(N








1
&











O
O
V

"O
1
O



















(N








cS
(L)
a











ON
ON
ON
oC
O
O
wo

"«


^ ^
OJ

i
^ J "^ -2 i
1 1 1 II
0> 'S *"* n "e
'• 5 o ° g
c £ -o — ' ^

« y •- ^ ""
— TO 3 f
3 W S- ^ -C
O. ^ u ^ c
O CO I- ID Q
CX t/3 (L> .^ C
"8 1 &2 ^.1
s s > § § «
JD y u ^ .2 u
§ o -g c* 2 u
>.£ u 't S |
o ffi "a. % g "
1 Q | 52 8 j=
^ ^ ^ a> *^ *-
v- J» "ed c/: ^
**- 00 s >> <; is
-a ^ -a " ^ g

.2 e « ^ ^ .2
o 1 1 S EC g
— DO 00 "^ t C
•— ' c C ^™ ^
III Jj 1
| 0 C 0 ^ >Q
K Ifli^
OX) t/5 V « '> C
5 5 s 5 "* ^
^* t- CT" r- « ^?
O "• C |^*|
'£ £ ° c '-S £
i t g | §E
1 ^ di * "1
- M ^ on re 15

-------
                          3.0 Very Small System Waiver
   This chapter covers:

          3.1    Qualifying for the VSS Waiver
          3.2    Selecting a Stage 2 Compliance Monitoring Site
          3.3    Next Steps: Preparing the Stage 2 DBPR Compliance Monitoring Plan
       EPA recognizes that very small systems typically have small distribution systems where
the high total trihalomethanc (TTHM) and high haloacetic acid-five (HAAS) levels occur at the
same location. For this reason, systems serving fewer than 500 people are automatically exempt
from IDSE requirements as long as the criteria in Section 3.1 are met, and EPA or your state
does not require otherwise.

       This chapter discusses the requirements for VSS waivers. These requirements arc also
outlined on your requirements summary sheet in Chapter 2 of this manual. Refer to Appendix
A if you arc a consecutive or wholesale system for specific issues that you should consider.

As long as you have TTHM and HAAS data, you arc qualified for the VSS Waiver. You have
NO further requirements for the IDSE unless EPA or your state tells you otherwise.	

3.1    Qualifying for the VSS Waiver

How can I qualify for the waiver?

       To automatically qualify for the VSS waiver, you must serve fewer than 500 people and
have taken TTHM and HAAS samples. VSS eligibility is not dependent on your Stage 1 DBPR
compliance monitoring or other TTHM or HAAS data results. The results do not have to be
below any particular level for you to receive the waiver.

What iff don't have Stage 1 compliance data, hut I have other TTHM & HAAS data?

       Some systems in combined distribution systems may not have conducted Stage 1 DBPR
compliance monitoring. If you have not conducted compliance monitoring but have other
TTHM and HAAS data, you should contact EPA  or the state to determine if this data is sufficient
to qualify for the waiver.  Some of the criteria that the reviewer might use to evaluate your data
are:

       •   Were samples analyzed by approved methods?
       •   Were samples analyzed at a certified laboratory?
       •   Are the sites located in areas of maximum residence  time?
       •   Were samples taken during the month of warmest water temperature?

IDSE Guide for Systems Serving < 10,000           ~1              :                 January 2006

-------
Consecutive systems that do not have any TTHM and HAAS data should check with their
wholesaler to determine if the wholesaler collected any TTHM and HAA5 data in their system.

What if EPA or the state contacts me and requires me to conduct an IDSE?

       Remember that even if you qualify for the VSS waiver, EPA or the state may require
you to conduct an IDSE.  IDSE sampling requirements for systems serving < 500 people are
minor compared to requirements for medium and large systems.  Standard monitoring for
systems serving < 500 people consists of preparing a monitoring plan, taking a dual sample set at
two distribution system locations during the peak month, and completing an IDSE report. Refer
to the Chapter 5 of this manual for guidance on conducting standard monitoring.

3.2    Selecting a Stage 2 DBPR Compliance Monitoring Site

       All systems serving <500 people are required to take one TTHM sample at the location
with the highest TTHM concentration, and one HAAS sample at the location with the highest
HAAS concentration. You can collect a dual sample set at one location if the highest TTHM
and HAAS concentrations occur at the same sample location and during the same month.

       EPA recommends that you consider using your Stage 1 monitoring location for Stage 2
DBPR compliance monitoring it if meets these criteria.  If you did not have a Stage 1 compliance
monitoring location, you should work with your state to select the best Stage 2 compliance
monitoring location(s). The high TTHM site will typically be an area of high residence time,
located at an extreme end or isolated portion of the distribution system. The high HAAS site will
often be at the same location, unless you have difficulty maintaining a distribution system
residual.  You should not select high HAAS sites in locations that regularly or in the summer
months have free chlorine residuals < 0.2 mg/L or chloraminc residuals < 0.5 mg/L.

3.3    Next Steps: Preparing the Stage 2 DBPR Compliance Monitoring Plan

          As the final step before you can begin compliance monitoring for the Stage 2 DBPR,
you must develop a Stage 2 DBPR compliance monitoring plan. The plan will be similar to
your Stage 1 DBPR monitoring plan in that it will identify how you intend to sample for
compliance with Stage 2. You do not need to submit the monitoring plan to EPA or your state,
but you must keep it on file for state and public review.  Note that Stage 1  DBPR compliance
monitoring requirements are in effect until you begin Stage 2 DBPR compliance monitoring.

       Because compliance  monitoring plans are not addressed as part of the IDSE provisions of
the Stage 2 DBPR, EPA has not included detailed guidance for developing Stage 2 compliance
monitoring plans in this guidance manual. EPA has developed the Stage 2 Disinfectant and
Disinfection Byproducts Rule: Small Entity Compliance Guide - One of the Simple Tools for
Effective Performance (STEP) Guide Series (draft version) to help you develop your monitoring
plan. See EPA's website at http://www.epa.gov/safewater/disinfcction/stage2 for an up-to-date
inventory of Stage 2 DBPR guidance manuals and training materials, or call the Safe Drinking
Water Hotline at  1-800-426-4791.
IDSE Guide for Systems Saving < 10,000          ~2January 2006

-------
                               4.0 40/30 Certification
     This chapter covers:

            4.1    Qualification Criteria
            4.2    Preparing and Submitting the Certification Letter
            4.3    Recordkeeping
            4.4    Selecting Stage 2 Compliance Monitoring Sites
            4.5    Preparing the Stage 2 DBPR Compliance Monitoring Plan
       Systems can qualify for the IDSE 40/30 certification if they have measured consistently
low total trihalomethane (TTHM) and haloacetic acid-five (HAAS) levels during Stage 1 DBPR
compliance monitoring. The term "40/30 " refers to a system having all individual Stage 1
DBPR compliance samples less than or equal to 0.040 milligrams per liter (mg/L) for TTHM and
0.030 mg/L for HAAS during a specific time period.

       If you qualify for the 40/30 certification and comply with the certification requirements,
and EPA or your state docs not notify you that you  need to conduct an IDSE, your system has
NO further requirements for the IDSE.  Your next steps will be to prepare a compliance
monitoring plan and begin  monitoring for the Stage 2 DBPR. You must continue with Stage 1
DBPR monitoring until you begin Stage 2 monitoring.

       If you have not already done so, complete the flowchart in Exhibit 2.3 of this guidance
manual before reading this  chapter. The flowchart directs you to a 2-pagc Requirements
Summary Sheet which contains compliance dates and additional requirements for complying
with the Stage 2 DBPR. You should keep your requirements summary sheet handy as you work
through this chapter.

       This chapter provides guidance on how to prepare and submit a 40/30 certification letter
and select Stage 2 DBPR compliance monitoring sites. If you are a consecutive or wholesale
system, refer to Appendix A for specific issues that you should consider.
IDSE Guide for Systems Serving < 10,000          4-1                               January 2006

-------
4.1    Qualification Criteria

       To be eligible for 40/30 certification, you must meet all of the following requirements for
the 8 consecutive quarter eligibility period shown in Exhibit 4.1.

       •   You have TTHM and HAA5 data equivalent to what is required by the Stage 1 DBPR
          for your system (e.g., quarterly, annual, or every third year)
       •   No individual sample exceeds 0.040 mg/L for TTHM
       •   No individual sample exceeds 0.030 mg/L for HAAS
       •   Your system did not have any TTHM or HAAS monitoring violations
                    Exhibit 4.1 40/30 Criteria Compliance Dates
Schedule1
1
2
3
4
Stage 1 DBPR
Data Eligibility Period2
8 consecutive calendar quarters starting
no earlier than January 2004
8 consecutive calendar quarters starting
no earlier than January 2005
40/30 Certification
Deadline
October 1 , 2006
April 1,2007
October 1 , 2007
April 1,2008
Notes:
1. Your schedule is defined by population served by your system or by the largest system in your combined
distribution system. See Chapter 2 for more information.
2. If you were not required to sample during this period, use data from the 12-month period prior to the eligibility
period shown.
       Example 4.1 is an example of a system determining whether they meet the 40/30 criteria.

       If you don't have Stage I  compliance data, EPA or your state may allow you to use
operational TTHM and HAAS data to qualify for 40/30 certification if your sampling and
analysis met the general intent of Stage 1 DBPR compliance.  These data should have been taken
and sampled in accordance with approved methods and at appropriate locations (i.e., maximum
residence time in the distribution system).

       Remember that even if you meet the eligibility criteria and submit the certification, EPA
or your state may still require you to conduct an IDSE using standard monitoring or an SSS. If
this occurs, you may need to work with EPA or your state to determine a schedule for
completing a standard monitoring or SSS plan and submitting an IDSE report.
IDSE Guide for Systems Sewing < 10,000
4-2
Januarv 2006

-------
                   Example 4.1  Qualifying for a 40/30 Certification

 A ground water system serving 8,000 people with two wells has been sampling annually at
 two locations in their distribution system under the Stage 1 DBPR.  Because they do not buy
 or sell water, this system is on schedule 4.  The table below shows their TTHM and HAAS
 data for their eligibility period.

Stage 1 Site 1
Stage 1 Site 2
July 2 1,2005
TTHM
(mg/L)
0.033
0.040
HAAS
(mg/L)
0.015
0.022
July 24, 2006
TTHM
(mg/L)
0.037
0.035
HAAS
(mg/L)
0.020
0.021
July 23, 2007
TTHM
(mg/L)
0.035
0.037
HAAS
(mg/L)
0.021
0.019
 No individual sample exceeded 0.040 mg/L for TTHM or 0.030 mg/L for HAAS.  The system
 does not have any TTHM or HAAS monitoring violations during the eligibility period. The
 system determines that they meet the criteria for the 40/30 certification and they submit their
 certification for the period of January 1, 2006 to December 31,  2007 by their deadline of April
 1,2008.
4.2    Preparing and Submitting the Certification Letter

       At a minimum, you must prepare and submit a statement certifying that you meet the
eligibility criteria in Section 4.1. Your certification should also contain basic system information
including population served by your system, your system type (subpart H or ground water,
community or non-community), and contact information. EPA has developed a 40/30
Certification Letter Form, shown on the next page, that can be used by any system to prepare a
certification letter.  This form is also available electronically as part of the IDSE Tool.
Example 4.2 is a completed certification form for a hypothetical  system.
The IDSE Tool creates a custom 40/30 certification form for your system and
submits the completed letter to EPA and your state for you.  The tool is available
on EPA's website at http://www.cpa.gov/safewatcr/disiniection/stage2.              iDSE-
IDSE Guide for Systems Serving < 10,000
4-3
January 2006

-------
40/30 Certification Letter Form  	                                    Page 1 of ll
STAGE 2 DBPR
US EPA-IPMC
P O Box 98
Dayton, OH  45401-0098

System Information

PWS Name:	PWS ID:	
Street Address:	Population Served:
City:	
State:	
Zip:	
Source Water Type:               ^Ground    DSubpart H
System Type:                           DCWS       DNTNCWS
Combined Distribution System:     ^Wholesale  ^Consecutive       dNcithcr

Contact Person

Name:	Title:	
Phone Number:	Fax Number (if available):	
Email Address (if availablc):_	

Certification

I hereby certify that each individual Stage 1 DBPR compliance sample collected from	
to	was less than or equal to 0.040 mg/L for TTHMand 0.030 mg/L for HAAS. I
understand that to be eligible, each individual sample must be equal to or below these values.  I
also certify that this PWS collected all required Stage 1 samples and did not have any Stage 1
monitoring violations during this time period.

Signature:	Date:	
IDSE Guide for Systems Serving < 10,000          4-4                                January 2006

-------
              Example 4.2  Completed 40/30 Certification Letter Form
 STAGE 2 DBPR
 US EPA-IPMC
 P O Box 98
 Dayton, OH 45401-0098

 System Information

 PWS Name:   Hometown	       PWS ID:  US 1234567
 Street Address:  987 Main Street          Population Served:  5.976
 City:	Hometown	
 State:     XX	
Zip:      12345
Source Water Type:               dGround     /Subpart H
System Type:                           /CWS       DNTNCWS
Combined Distribution System:     ^Wholesale  rJConsccutivc       /Neither

Contact Person

Name:   Jim Smith	            Title:     Certified Operator	
Phone Number:    987-6543	    Fax Number (if available):	
Email Address (if available):    J.smithy homctov\ n.gov

Certification

I hereby certify that each individual Stage 1 DBPR compliance sample collected from _
December 2005    to    November 2007   wax less than or equal to 0.040 mg/Lfor TTHM
and 0.030 mg/Lfor HAAS. I understand that to be eligible, each individual sample must be equal
to or below these values. I also certify that this PWS collected all required Stage 1 samples and
did not have any Stage 1 monitoring violations during this time period.

Signature:   ."   •'">'•'/	Date:	January 15. 2008	
IDSE Guide,for Systems Serving < 10.000          4-5                              January- 2006

-------
       You must submit your certification letter by the deadline in Exhibit 4.1.  You should
submit the certification to the Information Processing and Management Center (IPMC) for
review by EPA or your state. See Section 1.3 of this guidance manual for information on how to
submit your letter to the IPMC. If you do not submit either a 40/30 certification, standard
monitoring plan, or study plan by this deadline, you will incur a monitoring and reporting
violation. You can submit the letter as early as you want after you have met the requirements.

       EPA or your state may require you to submit additional information listed below:

       •   Stage 1 compliance monitoring results
       •   A distribution system schematic
       •   Recommended  Stage 2 compliance monitoring locations

If the reviewer wants to request additional information or to have you conduct an IDSE, they
will contact you. However, you may not receive a confirmation that your 40/30 certification has
been accepted. If you do not hear from EPA or your state within  12 months after the submission
deadline, you can assume your certification has been accepted.
4.3    Recordkeeping

       You must retain a complete copy of your 40/30 certification letter on
file for 10 years after you submit it to EPA or your state. You must also
make your 40/30 certification letter and any notification from EPA or your
state available for review by your state or the public.
4.4    Selecting Stage 2 Compliance Monitoring Sites

       After you submit your 40/30 certification letter, your next steps arc to select Stage 2
DBPR compliance monitoring sites and develop a monitoring plan. All systems serving fewer
than 10,000 people are required to select two compliance monitoring sites for the Stage 2
DBPR, one high TTHM site and one high HAAS site. Some small systems may be able to use
one location as both their highest TTHM and highest HAAS site if their highest concentrations
occur at the same location and during the same month. Refer to the second page of your
Requirements Summary Sheet in Chapter 2 for more information.

       Due to the change from plant-based monitoring under Stage 1 DBPR to population-based
monitoring for the Stage 2 DBPR, you may have the same number, more, or fewer monitoring
sites for Stage 2 compared to Stage 1.  Depending on how many Stage 1 sites you have, go to the
appropriate subsection (4.4.1, 4 4.2, or 4.4.3) for guidance on selecting Stage 2 DBPR
compliance monitoring sites.
IDSE Guide for Systems Serving < 10,000           4-6                                January 2006

-------
4.4.1   You Have THE SAME Number of Stage 1 Sites as Required by the Stage 2 DBPR

       If the number of Stage 1 DBPR monitoring locations in your system is exactly the same
as the required number of Stage 2 DBPR monitoring locations, continue to use all of your Stage
1 DBPR sites for Stage 2 DBPR compliance monitoring.

4.4.2   You Have MORE Stage 1 Sites than Required by the Stage 2 DBPR

       If you have more Stage 1  sites than you need for Stage 2 DBPR monitoring (this could be
the case if you have multiple treated entry points in your system), you must select the sites with
highest DBP levels for Stage 2 monitoring. You must alternate your site selection between
locations representing high TTHM levels and high HAAS levels, starting with high TTHM.

       To identify locations representing high TTHM levels and high HAA5 levels, EPA
recommends that you use Stage 1 DBPR monitoring results. Specifically, you can use the 3-Step
process outlined below:
Step 1:    Calculate the locational running
          annual average (LRAA) TTHM and
          HAAS concentrations at each Stage 1
          DBPR monitoring site. You should use
          data for the most recent calendar year,
          as long as this year is generally
          representative of typical system
          conditions.
       For systems collecting quarterly data:
       LRAA = (Ql  + 02+ Q3 + Q4) / 4

       For systems collecting annual data
       (once / year):
       LRAA - result for warmest temperature
Step 2:    Select the site with the highest TTHM LRAA as your high TTHM site

Step 3:    Select the site with the highest HAAS LRAA as your high HAAS site

4.4.3  You Have FEWER Stage 1 Sites than Required by the Stage 2 DBPR

       If you do not have enough Stage 1 sites to meet Stage 2 DBPR monitoring requirements,
you must select additional sites.  You must identify additional locations by alternating selection
of locations representing high TTHM and high HAAS levels, starting with high TTHM.
Remember that you will need to provide a justification for the new site selection in your Stage 2
compliance monitoring plan discussed in Section 4.5 below.

       When selecting new sites, you should consider site access issues, as each site should
remain accessible over the long term. You should also consider selecting sites that provide the
best geographic and hydraulic representation of your system. Additional guidance for selecting
high TTHM and high HAAS sites is provided on the next page.  If you have one Stage 1 site, it is
likely to be at a maximum residence time site which is typically representative of a high TTHM
location.  If this is the case, you should use the guidance below to select a high HAAS site.
Chapter 5 of this manual provides a more in-depth discussion of how to select these sites.
IDSE GuideJor Systems Sen'ing < 10,000
4-7
Januarv 2006

-------
High TTHM sites

       In general, higher water temperatures and increased water age lead to higher TTHM
concentrations. Storage facilities in a distribution system typically increase water age.
Therefore, if your system has storage tanks or reservoirs, you should locate high TTHM sites
downstream of those tanks. In addition, sites near dead ends and sparsely populated residential
areas can be likely sites for high TTHM.  Be sure to locate the sites before or at the last group of
customers on a dead end line. Samples taken at the very end of a dead end line are not
representative of the water received by customers.

High HAAS Sites

       As with TTHM, higher temperatures and increased residence time can lead'to higher
HAAS concentrations. However, HAAS can biodegrade where biological activity is present and
disinfectant residual levels are low or non-existent.  Therefore, you should consider locating high
HAAS sites where disinfectant residuals are significantly less than the system average
(indicating a long residence time), but avoid areas that have very low or no residual. When
booster disinfection is applied, the disinfectant residual will increase despite advanced water age.
Therefore, if your system practices booster disinfection, you should locate high HAAS sites after
booster disinfection is applied.

You should not select high HAAS sites in locations that regularly or in the  summer months have
free chjprinc residuals less than 0.2 mg/L or with chloraminc residuals less than 0.5 mg/L.	
4.5    Next Steps: Preparing the Stage 2 DBPR Compliance Monitoring Plan

       As the final step before you can begin compliance monitoring for the Stage 2 DBPR, you
must prepare a Stage 2 DBPR compliance monitoring plan. The plan will be similar to your
Stage 1 DBPR monitoring plan in that it will identify how you intend to sample for compliance
with Stage 2. You must keep your plan on file for state and public review. If you arc a subpart
H system serving > 3,300 people, you must also submit your plan to EPA or your state prior to
when you are required to start monitoring.

       Exhibit 4.2 contains the minimum requirements for what must be included in your Stage
2 DBPR compliance monitoring plan. Because compliance monitoring plans are not addressed
as part of the IDSE provisions of the Stage 2 DBPR, EPA has not included detailed guidance
for developing Stage 2 compliance monitoring plans in this guidance manual. EPA plans to
develop other manuals and training that specifically address the compliance monitoring
provisions of the Stage 2 DBPR.
IDSE Guide for Systems Serving < 10,000          4-8                                January 2006

-------
 Sec EPA's vvehsile at liUjv. _vw. w.opa.gm 'sai'c\vatcr-disinfcciion stagc2 for an up-to-date
 inventory of Stage 2 DBPR guidance manuals and training materials, or call the Safe Drinking
 Water Hotline at 1-800-426-4791.
   Exhibit 4.2 Required Contents of Stage 2 DBPR Compliance Monitoring Plans
       AH Systems
Additional Requirements for
 Systems Getting the 40/30
       Certification
Additional Requirements
  for Consecutive and
  Wholesale Systems '
     Monitoring
     locations
     Monitoring dates
     Compliance
     calculation
     procedures
  If you had FEWER Stage 1
  DBPR compliance monitoring
  sites than required by the
  Stage 2 DBPR, you must
  include the rationale for
  identifying locations as having
  high levels of TTHM or HAAS
  If your state has used its
  special primacy authority
  to modify your
  monitoring requirements,
  you must include
  monitoring plans for
  other systems in your
  combined distribution
  system
1.  See Appendix A of this manual for guidance specifically for consecutive and wholesale systems.
IDSE Guide for Systems Serving < 10,000
                                               Januarv 2006

-------
                               This page left intentionally blank
IDSE Guide for Systems Serving < 10,000           4-10                                   January 2006

-------
                             5.0  Standard Monitoring
      This chapter covers:

         5.1 Selecting Standard Monitoring Sites and Preparing Your Standard
             Monitoring Plan
                £D Standard Monitoring Plan Form for Systems Serving < 10,000
         5.2 Conducting Standard Monitoring
         5.3 Selecting Stage 2 DBPR Compliance Monitoring Sites and Preparing the
             IDSE Report
                £o Form for the IDSE Report for Standard Monitoring for Systems
                   Serving <]0,000
         5.4 Recordkeeping
         5.5 Next Step: Preparing the Stage 2 DBPR Compliance Monitoring Plan
       Standard monitoring is one year of increased distribution system monitoring to find
locations with high total trihalomcthanc (TTHM) and haloacetic acid-five (HAAS)
concentrations. Results from standard monitoring will be used in conjunction with results from
Stage 1 compliance monitoring to select Stage 2 compliance monitoring locations. Any system
can conduct standard monitoring to meet the IDSE requirements of the Stage 2 Disinfectants and
Disinfection Byproducts Rule (DBPR).

       The flowchart in Exhibit 2.3 will direct you to a 2-pagc Requirements Summaiy Sheet
for your IDSE schedule. You will also be directed to the Standard Monitoring Requirements -
Attachment sheet containing detailed requirements for standard monitoring and Stage 2
compliance monitoring (e.g., number of samples and sampling frequency). You should keep
these sheets handy as you work through this chapter.

       This chapter is specifically targeted to help systems serving < 10,000 people conduct
standard monitoring and select their Stage 2 DBPR compliance monitoring sites.  Additional
technical guidance is also provided in the IDSE Gudiance Manual (January 2006). It is
important that consecutive and wholesale systems communicate with each other throughout the
IDSE process. If you are a consecutive or wholesale system, refer to Appendix A for specific
issues that you should consider.

IMPORTANT: Results from IDSE standard monitoring should not be used to determine
compliance with maximum contaminant levels (MCLs) of the Stage 1 DBPR.  During the entire
IDSE period, you must continue to monitor according to your Stage 1 DBPR monitoring plan
and comply with Stage  1 DBPR MCLs at your Stage 1 sites.        	
IDSE Guide jor Systems Serving < 10.000          5-1                                January 2006

-------
5.1    Selecting Standard Monitoring Sites and Preparing Your Standard
       Monitoring Plan

       Every system that conducts IDSE standard monitoring must prepare and submit a
Standard Monitoring Plan. You should submit the plan to the Information Processing and
Management Center (IPMC) for review by EPA or your state.  See Section 1.3 of this guidance
manual for information on how to submit your plan to the IPMC.

       This section contains EPA's recommended technical approach for selecting standard
monitoring sites. It also contains the recommended approach for selecting the peak historical
month and scheduling standard monitoring.  Lastly, this section provides guidance on
completing the IDSE standard monitoring plan.

       EPA has developed a Standard Monitoring Plan Form for Systems Serving < 10,000,
presented in Section 5.1.3 and available electronically as part of the IDSE Tool. You are not
required to use this form; however, if you  choose not to use it, refer to Exhibit 5.1 for a list of the
minimum elements you must include in your standard monitoring plan.  The IDSE Tool is
available on EPA's website at  http://www.ena.uov/salevvatcr/disinfection/staui^
         Exhibit 5.1 Required Elements of Your Standard Monitoring Plan

        •    The population served by your system
        •    Your system type (subpart H or ground water)
        •    A distribution system schematic showing
            -  entry points
            -  sources
            -  storage facilities
            -  locations and dates of all projected standard monitoring and Stage 1 DBPR
               compliance samples
            Peak historical month
        •    Justification of standard monitoring site selection and a summary of data you
            relied on to justify standard monitoring site selection
IDSE Guide for Systems Serving < 10,000           5-2                                January 2006

-------
5.1.1  Recommended Approach for Selecting Standard Monitoring Sites

       You arc required to select up to four types of standard monitoring sites for the IDSE:
near entry point sites, average residence time sites, high TTHM sites, and high HAAS sites. See
Exhibit 5.2 below for how many of each type of site arc required for your system (this
information is repeated in Chapter 2). Note that the number of sites and frequency of sampling
is based on the population served by your system, not the population served by the largest
system in your combined distribution system.
                 Exhibit 5.2 IDSE Standard Monitoring Requirements
Source
Water
Type
Subpart H
Ground
Water
Population Size
Category1
<500 consecutive
systems
<500 non-
consccutive systems
500-3,300
consecutive systems
500-3,300 non-
consecutive systems
3,301-9,999
<500 consecutive
systems
<500 non-
consecutive systems
500-9,999
Monitoring
Periods and
Frequency of
Sampling
one (during
peak historical
month)1
four (every 90
days)
one (during
peak historical
month)1
four (every 90
days)
Distribution System Monitoring Locations2
Total per
monitoring
period
2
2
2
2
4
2
2
2
Near
Entry
Points
1


1




1




Average
Residence
Time








1






High
TTHM
1
1
1
1
2
1
1
1
High
HAAS


1


1
1


1
1
1 Your monitoring requirements (locations and frequency) are based on the population served by your system
2 A dual sample set (i.e., a TTHM and an HAAS sample) must be taken at each monitoring location during each monitoring period
3 The peak histoncal month is the month with the highest TTHM or HAAS levels or the warmest water temperature
       EPA's recommended 8-Step technical approach for selecting standard monitoring sites
is shown in Exhibit 5.3. EPA recommends that you use tools and data sources available to select
at least twice as many candidate sites as required for standard monitoring in Steps 3, 4, and 5.
You may want to map and color-code your candidate sites as you select them to ensure that your
distribution system is fully represented.  Later, you can use additional criteria to select the most
representative standard monitoring sites from these candidate sites (see Step 7).

The remainder of this section contains detailed guidance for each of these eight steps.
IDSE GuideJor Systems Serving < 10,000
5-3
Januan' 2006

-------
   Exhibit 5.3  Recommended Approach to Selecting Standard Monitoring Sites

Step 1 : Gather Data
and Tools
-Water quality data
-System information
V J
I

4444
     Step 2: Select
      Near Entry
      Point Sites
      (for consecutive
      systems only)
 Step 3: Select
Candidate Sites
       for
Average Residence
      Time
  Step 4: Select
 Candidate Sites
        for
     High TTHM
\	J
 Step 5: Select
Candidate Sites
       for
    High HAAS
                                   Step 6: Plot
                                 Candidate Sites
                               Plot near entry poinf and
                                  candidate sites
                               Also plot Stage 1 compliance
                                   monitoring sites       J

                              1         I        ^
                                  Step 7: Select
                                    Standard
                                 Monitoring Sites
                                  Step 8: Write
                                justification and
                                summary of data
Remember that Stage 1  DBPR compliance monitoring sites cannot be used as standard
monitoring sites.	^	
IDSE Guide jor Systems Serving < 10,000
                 5-4
            Januarv 2006

-------
 Step 1: Gather Data and Tools

       There are many kinds of data and tools that can be useful in selecting standard
 monitoring sites.  Exhibit 5.4 shows the types of information typically available to water systems
 and for which types of sites they should be used.

       One of the most important tools you can use to select standard monitoring sites is an up-
 to-date, detailed map of your distribution system. When you submit your standard monitoring
 plan, you are required to  include a schematic of your distribution system showing all entry
 points, sources and storage facilities. Other useful map features include the layout of pipes,
 locations pump stations, pressure zone boundaries, locations of large users, and population
 density information.  For security reasons, EPA recommends that you remove any information
 that could pose a  security risk from your standard monitoring plan submittal. You may wish to
 use a separate, working version of your distribution system map for selecting sites, then transfer
 your information  to a less detailed map for your standard monitoring plan submittal.

       It is important that you consider available water quality data from your distribution
 system when selecting standard monitoring sites. In general, your water quality data should be
 less than 10 years old and should represent current system configurations to the extent possible.
 Most systems have collected disinfectant residual data from their distribution system, and this
 data can be very useful for selecting standard monitoring locations. EPA has provided additional
 guidelines for evaluating  disinfectant residual data in Step 3.

       Some systems, such as those that serve resort communities, have dramatic fluctuations in
 flow as well as population.  If your system experiences widely  varying demands on a seasonal
 basis, you should evaluate data and operational information for different seasons separately.
 When you arc selecting sites, make sure that you select sites that represent the different operating
 scenarios of your  system.

       A key resource available to many systems is the experience and knowledge of water
 system personnel. Because distribution system operations and configuration arc not always
 well documented, experienced operations personnel can provide valuable insights to the site
 selection process.

       Some systems may have advanced tools available, namely:

       •   A hydraulic model
          Results from a distribution system tracer study

 If you have these advanced tools, refer to the IDSE Guidance Manual for suggestions on how
 you can use these  tools to select standard monitoring sites.
IDSE Guide jor Systems Serving < 10,000           5-5                                 Januaiy 2006

-------
            Exhibit 5.4 Data and Tools for Delecting Different Types of
                             Standard Monitoring Sites
Type of Information
Type of Standard Monitoring Site
Near Entry
Point
Average
Residence Time
High
TTHM
High
HAAS
System Configuration
Pipe layout, location of storage facilities
Location of sources
Pressure Zones
Information on Population Density
Locations of Large Customers

X



X
X
X
X
X
X
X
X
X

X
X
X
X

Water Quality and Operational Data
Disinfectant Residual Data
Stage 1 DBP Data
Other DBP Data
Microbiological Monitoring Data (e.g., HPC)
Tank Level Data, Pump Run Times
Customer Billing Records






X



X
X
X
X
X

X
X
X
X
X
X
X
X
Step 2:  Identify Near Entry Point Standard Monitoring Sites
(For Consecutive Systems Only)

      A consecutive system is defined in the Stage 2 rule as a public water system that receives
some or all of its finished water from one or more wholesale systems. If you are a consecutive
system serving fewer than 3,300 people, you must monitor at or near the connection to your
wholesale system and before the first customer. This will give you valuable information on
TTHM and HAAS levels coming into your system.  If you do not have a sample tap prior to your
first customer, consider using your first customer as your near entry point site.  If you have more
than  one connection to a wholesale system, you should select the best connection to monitor
based on a combination of the fallowing:

      •   Annual flow (e.g., use the source with the highest flow in your system)
          Water quality (e.g.,  if you buy from one surface water system and one ground water
          system, monitor at the connection to your surface water system).

See Appendix A for additional  guidance specifically for consecutive systems.
IDSE Guide for Systems Serving < 10,000
5-6
January 2006

-------
Step 3: Identify Candidate Average Residence Time Sites

       Average residence time is the average age of water delivered to customers in a
distribution system.  Average residence time is not simply one-half the maximum residence time.
One way to locate average residence time sites is to calculate average disinfectant residual
concentration in your system, then identify sites with residual concentrations near the average.
When calculating the average disinfectant residual concentration, it is important that you use
data from sites that are representative of the entire distribution system. You can do this using
residual data from TCR monitoring sites.  This data should be useful since the TCR requires that
monitoring sites represent water throughout the distribution system.

       See the guidelines in Exhibit 5.5 for using disinfectant residual data.  If you have good
disinfectant residual  data from multiple TCR sites in your distribution system, you can use the
following 3-step procedure to locate average residence time sites:

       1)  Calculate an average disinfectant residual at each of the TCR sites using data from
           the summer months (e.g., June, July, and August).

       2)  Using averages from the individual sites, calculate an overall average distribution
           system residual concentration.

       3)  Sites with an average residual close to the distribution system average can be
           considered representative of average residence time in the distribution system.  Select
           sites in areas with high population densities with disinfectant residuals close to the
           system average.

You should be careful when analyzing chloramine residual data. Chloramincs arc generally
more stable than chlorine, and small changes in residual concentrations may not be signficant.

       Another way  to select average residence time sites is by using billing records and a map.
You should begin by identifying service areas with the most development. You can examine
your customer billing records to determine where your large customers are located. The portions
of the distribution system serving large water users will likely have low water age and will not
be good candidate sites for average residence time.  If your system does not have any large
individual customers, consider locating your candidate average residence time sites in highly
developed areas in the approximate geographic center of the distribution system.
IDSE Guide for Systems Serving < 10,000           5- 7                                Januaiy 2006

-------
             Exhibit 5.5 Guidelines for Using Disinfectant Residual Data

 When should I use disinfectant residual data?

        Disinfectant residual in the distribution system generally decays as water age increases.
 Residual concentrations typically decay faster in the warmer months, and the magnitude of
 decay is more pronounced for free chlorine residuals compared to chloramine residuals.

        Disinfectant residual can be helpful in locating areas of average and maximum
 residence time in the distribution system.  This information can be used to select candidate
 average residence time, high TTHM, and high HAAS sites.

        Because disinfectant residual decay can be caused by factors other than residence time,
 you should be careful when interpreting your data. Other reasons why you might sec a loss in
 disinfectant residual are listed below.

        •   Certain types of pipe material can exert a disinfectant residual demand. In
           particular, unlincd cast iron pipe can cause residuals to decline.
        •   Residual decline can be caused by corrosion byproducts and sediment.
        •   Bacteriological activity can result in a significant depletion of disinfectant residual.

 What are the sources of disinfectant residual data?

        Residual data can be from TCR sites. Stage 1 sites, operational sample sites, or sites
 sampled following customer complaints.

 Which data should I use to help identify candidate average residence time sites?

        If you arc using residual data to help identify sites with average water age, make sure
 that data  is from locations distributed throughout the system. You may want to use only data
 from TCR sites, since these sites should be geographically representative of your system.
 Make sure you don't over emphasize a particular area. You should also use data from the
 warmest months that show the biggest differences in residual levels.

 What if I don't have residual data throughout the system?

        You may wish to take more residual data. Take care to ensure that the data is
 comparable in terms of analytical method, distribution system configuration, and time of the
 year to the data to which it will be compared.
IDSE Guide,for Systems Sewing < 10,000           5-8                                January 2006

-------
 Step 4: Identify Candidate High TTHM Sites

       It is not the intent of IDSE monitoring to identify sites with maximum daily or hourly
 TTHM concentrations.  Instead, you should choose candidate sites to represent areas of the
 distribution system where you expect to find the highest TTHM levels throughout the year.

       In general, higher water temperatures  and increased water age lead to higher TTHM
 concentrations in distribution systems.  The following guidelines can be used to select high
 TTHM sites.

 Use your distribution system map
 •      If your system has booster disinfection, you should locate
       candidate high TTHM sites after booster disinfection has been
       applied (additional disinfectant may have increased DBF
       formation).

 •      If your system has storage tanks or reservoirs, you should locate
       candidate high TTHM sites hydraulically downstream of those
       tanks or reservoirs.

 •      You should locate candidate sites near dead ends, particularly
       those that arc on smaller lines, far from major transmission lines.
       Sparsely populated residential areas  can be good candidate sites
       for high TTHM. However, be sure to locate the candidate sites
       before or at the last group of customers on a dead end line.
       Samples taken at the very end of a dead end line arc not
       representative of the water received by customers.

 Use residual disinfectant data
•      You should locate high TTHM sites in areas with low disinfectant residual, or with
       residual concentrations that are significantly less than average. (See Step 3 of this
       section for how to calculate the system average disinfectant residual.)  The low residual
       may indicate a long residence time. Be careful when interpreting disinfectant residual
       data because there are other conditions other than water age that can result in low
       residuals in the distribution system (see Exhibit 5.5).

Use additional water quality data and/or advanced tools

•      Hydraulic models and tracer studies can be very useful  in selecting candidate high
       TTHM sites.  If one or more of these tools are available to your system, refer to Chapter
       7 of the IDSE Guidance Manual
                            Locate candidate
                            high TTHM and
                               HAAS sites
                          downstream oj tanks
IDSE Guide for Systems Serving < 10,000
5-9
Januarv 2006

-------
Step 5: Identify Candidate High HAAS Standard Monitoring Sites

       As with high TTHM standard monitoring sites, it is not the intent of IDSE monitoring to
identify sites with maximum daily or hourly HAAS concentrations. Instead, you should choose
high HAAS standard monitoring sites to represent areas  of the distribution system where you
expect to find the highest HAAS levels throughout the year.

       Higher temperatures and increased residence time can lead to higher HAAS
concentrations. However, microorganisms can consume HAAS, causing levels to decrease. This
is know as biodegradation.  Biodcgradation is more likely to occur when disinfectant residual
levels are low or non-existent, particularly in warmer months.  Therefore, a high HAAS site will
not necessarily be the site with the longest residence time. You can use the following guidelines
to select high HAAS sites.

Review historical HAAS data

       One way to determine if HAAS biodegrades in your system is to examine Stage 1 DBPR
monitoring or other HAAS data. You should evaluate the data over time at different locations in
the distribution system to look for trends.  Consider evaluating your data to answer the following
questions:

       Arc the highest HAAS levels typically in the summer months (if you monitor more than
once per year)?
       •  Arc your HAAS levels at your Stage 1 DBPR maximum residence time site higher
          than at your treatment plant (if you monitor at the treatment plant)?
       •  Do the highest HAAS  generally occur at the same time of year and locations as high
          TTHM values?

If you answered "yes" to all of these questions, it is unlikely that you arc experiencing
biodegrcdation of HAAS . If you answered "no" to any of these questions, HAAS compounds
may be degrading in your system due to biological activity.  It is important that you also
evaluate disinfectant residual data to determine the potential for biodegradation in your
distribution system.

You should not select high HAAS sites in locations that regularly or in the summer months have
free chlorine residuals less than 0.2 mg/L or with chloraminc residuals less than 0.5 mg/L.	

If you don't believe that HAAS biodegrades in your system

       High HAAS sites will be similar to high TTHM sites. You should use the principles in
Step 4 to select high HAAS sites. Remember, high HAAS sites must be different from high
TTHM sites for standard monitoring.
IDSE Guide for Systems Serving < 10,000           5-10                                January 2006

-------
 If you do helicvc that HAA5 biodegrades in your system

        You should consider locating HAA5 sites in areas with lower water age in the center
 regions of your system where you maintain high disinfectant residuals.

 Step 6:  Plot Sites on a Distribution System Map

        A key step in selecting standard monitoring sites from candidate sites is plotting all
 candidate sites on a map of your distribution system. If you have not already done so, locate all
 Stage 1 DBPR compliance monitoring locations, near entry point sites, and candidate average
 residence time, high TTHM, and high HAAS sites on your water distribution map. Consider
 color coding the sites by the site type.

       As noted in Step 1, your map should also contain  the system attributes that will be useful
 in identifying representative standard monitoring sites,  such as:

       •   Layout of pipes
       •   Storage facilities
       •   Pumping stations
           Booster disinfection stations
       •   Pressure zone boundaries

 If possible, your map should also include the location of large water users, areas of significant
 development, and areas with relatively few customers.

 Step 7: Select Standard Monitoring Sites from Candidate Sites

       You should now have identified more candidate average residence time, high TTHM, and
 high HAAS sites than are required for standard monitoring. Your next step is to narrow down
 your candidate sites to select standard monitoring sites. This section addresses this question by
 providing general guidelines for (1) evaluating sites and determining if they meet expectations,
 and (2) narrowing down the candidate sites to  standard  monitoring sites.  Remember that  you
 must write a justification for each standard monitoring site and a summary of data considered
 (see Step 8), to be included in your IDSE standard monitoring plan. You may want to consider
 how you will write your justifications as you examine your candidate sites.

 IMPORTANT: You should always visually confirm that standard monitoring sites, in
 combination with existing  Stage 1 DBPR monitoring sites, provide geographic coverage of the
 distribution system. You should confirm that you are not missing key areas that may not  have
 been sampled in the past.	

Evaluate Sites.  Do They Meet Expectations?

       •  Are candidate high TTHM sites located in the extremities of the distribution system?
IDSE GuideJor Systems Serving < 10.000          5-11                                Januaiy 2006

-------
       •   Arc candidate high TT1IM sites generally downstream of storage facilities and
           booster disinfection stations (if booster disinfection is practiced)?

       •   Are candidate high HAAS sites in areas where you can regularly maintain
           disinfectant residual levels greater than 0.2 mg/L for chlorine and 0.5 mg/L for
           chloramine?

       •   Arc there any other areas where you suspect water age is high that are not represented
           by a candidate high TTHM (and possibly high HAAS) site?

Narrow Down Candidate Sites to Select Standard Monitoring Sites

       •   Look for geographic representation. Select sites that are geographically diverse
           from the other standard monitoring sites and existing Stage 1 compliance monitoring
           locations.  EPA recommends that you locate at least one of the high TTHM standard
           monitoring sites in a remote area of the distribution system. If your distribution
           system contains hydraulically isolated portions, you should represent as many of
           these as possible with at least one standard monitoring site.  If you arc only required
           to select one high TTHM site, it is strongly recommended that you locate this site far
           away from the treatment plant, near the last group of customers (but prior to the last
           fire  hydrant).

       •   Look for hydraulic representation.  Select standard monitoring sites in
           hydraulically different areas. Even if sites arc geographically near each other, they
           may represent different pressure zones.  You should also select sites that represent
           mixing zones if multiple sources with different water quality characteristics arc used.

       •   Use sites that "multi-task." Prioritize sites that meet the multiple siting criteria and
           those identified based on more than one data source.  For example, a candidate high
           TTHM site that has low disinfectant residual,  is near the edge of the distribution
           system and is downstream of a tank would be an  excellent standard monitoring site.

           Consider site access.  Select standard monitoring sites for which access will not be
           an issue. Sites should remain accessible over the long term.

Step 8: Write Justifications and  a Summary of Data

       Your final steps in selecting standard monitoring  sites are to write a justification for each
site and write the summary of data you used to justify your site selection.

       You must write a justification for each  standard monitoring site. Justifications should
document the key site characteristics that led you to select the site for standard monitoring. They
should be brief, but as specific as possible. Some characteristics you should consider including
in your justifications are as follows:
1DSE Guide for Systems Sei-ving < 10,000           5-12                                 January 2006

-------
       •   Pipe size, or range of pipe sizes in the area
       •   Relationship to storage facilities
       •   Estimated water age, if available
       •   Source of water (if the distribution system is served by more than one source)
           Range of disinfectant residual concentrations (if lower in the summer, provide
           summer values)
       •   For HAA5 sites, range of HPC levels, if available

Not all systems will have all data types in this list; include the information that is available to
your system in your justification.

       Hypothetical examples of justifications for each type of standard monitoring site are
below.  Additional examples of justifications are provided in Appendix B of this guidance
manual and in the IDSE Guidance Manual.

       •   High TTHM site: This site is near the end of our distribution system on a 6-inch
           main and down-gradient of Tank K.  Chlorine residuals at this site range from 0.5 to
           1.0 mg/L in the summer, compared to our system summer average of 2.0 mg/L.

       •   Hish HAA5 site: This site is on an 8-inch pipe in a commercial area.  This site is far
           from our treatment plant, hut it always has a delectable chlorine residual.

       •   Average  residence time site: This site is in the geographic center of Pressure Zone 2
           and has a chlorine residual level close to the system average (2.0 mg/L).

       •   Near entry point: This site is at the master meter where we purchase water from
           System Y. We are connected to System Y at another location, hut this connection has
           the highest flow.

       In addition to justifications, you must provide a summary of data you relied on to justify
standard monitoring location selection. You should describe the water quality data you
reviewed, map features you considered, ranges of relevant water quality data, and water sources
and seasonal operations if applicable, and tools you used to select your standard monitoring sites.
An example summary is provided below.  Additional examples of data summaries are provided
in Appendix B of this guidance manual and in the IDSE Guidance Manual.

       We  used our water distribution system map to plot data and select sites. Our map shows
       locations of our large transmission mains, two storage tanks, and our surface water
       source. It also shows locations of TCR and Stage I monitoring sites. We analyzed
       disinfectant residual collected at TCR sites in 2004 and 2005. Summer disinfectant levels
       ranged from  2.5 mg/L at the plant to 0.3 mg/L in the distribution system, with a
       distribution system average of LI mg/L in July and August.  We calculated average
       TTHM and HAA5  concentrations for our Stage 1 DBPR sites for 2005 data.  TTHM
       concentrations ranged from 0.035 mg/L through 0.085 mg/L and HAAS concentrations
       ranged from  0.015 mg/L through 0.037 mg/L. We looked at tank level data to estimate
       average residence time inside our t\vo tanks. We highlighted two problem areas that our
IDSE Guide for Systems Serving < 10,000           5-13                                January- 2006

-------
       operations staff say arc places where we get repeat ens tamer complaints of stale or dirty
       water and low disinfectant residuals.
5.1.2   Selecting Your Peak Historical Month and Determining Standard Monitoring
       Schedule

Determining Peak Historical Month

       The Stage 2 DBPR defines the peak historical month as the month with the highest
TTHM or HAAS levels or the warmest water temperature. It is meant to represent "worst case"
conditions when DBFs are the highest. You must review available compliance, study, or
operational data to determine the peak historical month for TTHM or HAAS levels or warmest
water temperature.  You can use Worksheet 5.1 on the next page to determine your peak
historical month.

       Some systems may find other data, such as total organic carbon (TOC) data and water
demand data, helpful in determining the peak historical month. If you wish to consider data
other than TTHM, HAAS, and temperature data for selecting your peak historical month, sec
Chapter 7 of the IDSE guidance manual for guidance.

Determining Standard Monitoring Schedule

       You must take one round of standard monitoring samples during the peak historical
month.  If you serve between 500 and 9,999 people, you must also conduct sampling  at equal 90-
day intervals before and/or after the peak historical month. Be sure to plan your monitoring so
that all sampling is complete by the deadline on your requirements summary sheet in Chapter 2.

       The intent of the required time interval is to ensure that samples represent the quality of
water over an extended period and do not over-emphasize either high or low concentrations  of
TTHM or HAAS that may occur seasonally. For example, a system on quarterly monitoring
could sample in the third full week of every third month.  You should keep in mind holidays
and sampling schedules for other water quality programs when determining your standard
monitoring schedule.
IDSE Guide for Systems Sewing < 10.000          5-14                                January 2006

-------
 Worksheet 5.1  Selecting the Peak Historical Month	Paec ' ot
 A.  Do you have more than one water source (e.g., treatment plant
 or consecutive system entry point) in your system?                 D Yes    D No

        If Yes, you should identify the source associated with the highest
        TTHM and HAAS levels in your system based on your Stage 1
        DBPR monitoring data. You should use data from this source for
        selecting your peak historical month. Continue to STEP B

        If No, continue to STEP B
 B.  Do you have monthly or quarterly TTHM and HAAS data?        D Yes    D No

        If Yes, you should determine in which month your TTHM and HAAS levels are the
        highest.

             What if the highest TTHM and/or HAAS levels occur at different times during
             different years? You should choose the year of data that is most representative
             of typical system operating and weather conditions.

             What if the highest TTHM and HAA5 levels occur in different months? You
             should consider which contaminant is of more concern.  If one contaminant
             clearly shows a higher overall trend and is closer to the MCL, you should
             choose the month in which that contaminant is highest.

        Choose the month with the highest TTHM and HAAS levels as  your peak
        historical month. Stop here.
        If No, continue to STEP C
 C.  Use temperature data to select your peak historical month

       Calculate the average water temperature for each summer month to identify the
       month of warmest water temperature.  If available, use data from several years to
       determine when the warmest water temperature occurs.  If warmest
       temperature occurs in different months in different years, select the year(s)
       that are most typical of climatological and water quality data and water use
       for your region.


       Remember, in your standard monitoring plan you should indicate the source used to
       select your peak historical month and the basis for selecting it (high TTHM, high
       HAAS, and/or temperature)
IDSE Guide jor Systems Serving < 10,000          5-75                              January 2006

-------
5.1.3   Preparing Your Standard Monitoring Plan

       Every system that conducts IDSE standard monitoring must prepare and submit an
Standard Monitoring Plan.  You should submit the plan to the Information Processing and
Management Center (IPMC) for review by EPA or your state.  See Section 1.3 of this guidance
manual for information on how to submit your plan to the IPMC.

       EPA has developed a Standard Monitoring Plan Form for Systems Serving < 10,000,
presented in this section and available electronically as part of the IDSE Tool.  You are not
required to use this form; however, if you choose not to use it, refer to Exhibit 5.1 on page 5-2
for a list of the minimum elements you must include in your standard monitoring plan.
       The IDSE Tool creates a custom form for your system and provides
links to technical guidance from this manual. The tool is available on EPA's
website at http://www.cpa. gov/safcwatcr/disinfcction/stagc2.                    IDSE j00i
       Your deadlines for submitting your standard monitoring plan and conducting standard
monitoring can be found on your requirements summary sheet in Chapter 2. If EPA or your state
docs not approve or request modifications to your plan, or notify you that your plan is still under
review within 12 months after the deadline for plan submission, you may consider the plan
approved.

       The standard monitoring plan form includes the following sections:

       I.     General Information
       II.     IDSE Requirements
       III.           Selecting Standard Monitoring Sites
       IV.    Justification of Standard Monitoring Sites
       V.     Peak Historical Month and Standard Monitoring Schedule
       VI.    Planned Stage 1 DBPR Compliance Monitoring Schedule
       VII.   Distribution System Schematic
       VIII.   Attachments

Sections of the form with an asterisk (*) are required by the Stage 2 DBPR.  Examples of
completed standard monitoring plans using this form are provided in Appendix B of this manual
and in the IDSE Guidance Manual. The rest of this section provides guidance on the completion
of this form.

I.      General Information

       I.A.   PWS Information* - Important definitions for classifying your system are
             provided in the definitions section at the beginning of this guidance manual.  If
             you have any questions on this section, contact EPA or your state.

IDSE Guide for Systems Sewing < 10.000          ~5^16January 2006

-------
              PWS1D - Enter your PWSID identification number here. This number is typically
              assigned by your state.

              PWS Name - Enter the name of your system here.

              PWS Address - Enter the primary mailing address for your water system here.

              Population Served - Enter the number of people served by your PWS.
              Remember, this is your RETAIL population served, not including the population
              served by consecutive systems that purchase water from you.

              System Type - Put a check mark in the appropriate box to identify whether your
              system is a CWS or a NTNCWS. Definitions for CWS and NTNCWS can be
              found in the definitions section at the beginning of this guidance manual.

              Source Water Type - Put a check mark in the appropriate box to identify whether
              your system is a subpart H system or a ground water system. If you use any
              surface water or GWUDI as a source, mark the subpart H box.  Definitions for
              subpart H system (including GWUDI) and ground water system can be found in
              the definitions section at the beginning of this guidance manual.

              Buying/Selling Relationships - Put a check mark in the appropriate box to identify
              whether your system is a consecutive system, a wholesale system, or neither. If
              you arc both a consecutive and wholesale system (e.g., you buy and sell water),
              check  both boxes. Definitions for consecutive system and wholesale system can
              be found in the definitions section at the beginning of this guidance manual and
              in Appendix A.

       l.B.    Date Submitted* - Enter cither the date that you are submitting the form
              electronically, putting it in the mailbox, or dropping it off with an express
              delivery service.  Be sure to submit your standard monitoring plan before the
              deadline found on your requirements summary sheet.

       I.C.    PWS Operations - This section asks questions about your system to help inform
              EPA and state personnel during the plan review process.

              Residual Disinfectant Type - Put a check mark in the appropriate box to identify
              the type of disinfectant you most often use to maintain a residual in your
              distribution system (not necessarily the same disinfectant used for primary
              disinfection at the treatment plant). If you use chloramine but switch to free
              chlorine for a short time, you should still check chloramine only. If you use
              chloramine and chlorine regularly in your  system (e.g, 4 months of free chlorine
              and 8 months of chloramines), check both  chlorine and chloramine.  If you
              maintain your residual with a disinfectant other than chlorine or chloramines (e.g.,
IDSE Guide jor Systems Sewing <- 10,000           5-17                                January 2006

-------
              chlorine dioxide), you should place a check next to the box marked "Other" and
              enter the type of disinfectant you use in the blank next to "Other".

              Number of Disinfected Sources - Enter the total number of sources that deliver
              disinfected water to your distribution system. If you connect to a single
              wholesale  system at a number of locations in your distribution system, consider
              this one source.  Multiple wells that are disinfected at a common treatment plant
              should also be considered one source.  Do not count wells that are not disinfected
              or arc disinfected by UV only.

       I.D.    Contact Person* - Enter the contact information of the person who is submitting
              the form. This should be the person who will be available to answer questions
              from EPA  and/or state reviewers.

II.     IDSE Requirements*

       II.A    Number of Sites - Refer to Exhibit 5.2. Copy the numbers from the exhibit that
              correspond to your source type and the population served by your system. This
              information is also in Chapter 2 of this manual.

       II.B.   Schedule - Enter the schedule for your system based on the letter sent to you
              from EPA  or your state. Sec Chapter 2 for more information on the letter.

       II.C.   Standard Monitoring Frequency - Locate the monitoring frequency from Exhibit
              5.2 that corresponds to your source type and the population served by your
              system.  Put a check mark in the box corresponding to that monitoring frequency.
              This information is also in Chapter 2 of this manual.

HI.    Selecting Standard Monitoring Sites

       III.A.  Data Evaluated - Put a check mark in each box corresponding to the data that you
              used to select each type of standard monitoring site. Water quality data may be
              compliance data or operational data.

       III.B.  Summary of Data* - In the space provided (or in an attached writeup), provide a
              summary of the data you used to justify your site selection.  See  Step 8 in Section
              5.1.1 of this manual for guidance.

IV.    Justification of Standard Monitoring Sites* Enter the site ID from the distribution
       schematic, site type (whether it is near an entry point, average residence  time, high
       TTHM, or high HAAS), and justification.  Justification for each standard monitoring site
       should include the system characteristics that  led you to choose it as a standard
       monitoring site. See Step 8 in Section 5.1.1 of this manual for guidance.
IDSE Guide for Systems Serving < 10,000          5-18                               Januaiy 2006

-------
V.     Peak Historical Month and Proposed Standard Monitoring Schedule

       V.A.   Peak Historical Month* - Enter the month that you determined to be your peak
              historical month. See Section 5.1.2 and Worksheet 5.1 for guidelines on
              selecting your peak historical month.

       V.B.   If Multiple Sources, Source Used for Peak Historical Month - If your system has
              only one source, write "N/A" here. If you have more than one source, write the
              name of the source you used as the basis for determining peak historical month.
              For example, if a system has one surface water,  one ground water, and one
              purchased ground water source, it is likely that they relied heavily on data from
              the surface water source to select their peak historical month. This system would
              write "surface water source" in the blank provided.

       V.C    Peak Historical Month Based On* - Put a check mark in the appropriate box to
              identify the basis for determining your peak historical month. If your peak
              historical month is supported by more than one parameter (e.g., peak historical
              month is month of high TTHM and maximum temperature), check each box that
              applies.  If you used data other than TTHM, HAAS, and temperature data to
              select your peak historical month (e.g., you used TOC data and/or water age
              data), describe how you used additional data here.

       V. D.   Proposed Standard Monitoring Schedule* - Enter the ID for each standard
              monitoring site in the table (verify that these match the ID's you enter in Section
              IV and on your schematic).  Enter your proposed sampling schedule for the
              number of monitoring periods identified in Section II.C. The entry can be a
              specific date or week and can be in a number of different formats. For example:

                    7/9/07
                    2nd week in Nov '07
                    Week of 7/9/07

              Remember that at least one monitoring period must be during the peak historical
              month identified in Section V.A.

VI.    Planned Stage 1 DBPR Compliance Monitoring Schedule* Enter the projected
       sampling schedule for the number of Stage 1 DBPR monitoring periods in which you will
       conduct Stage 1  DBPR monitoring during your IDSE standard monitoring. Verify that
       site IDs in this table match the IDs on your distribution  system schematic.  If you are
       required to monitor at more than 8 Stage 1 DBPR locations you will need to attach
       additional sheets. You may also want to attach your Stage 1 DBPR monitoring plan.

VII.   Distribution System Schematic* Attach a distribution system schematic to your
       monitoring plan. Your schematic must include the locations of entry points, sources,
       storage facilities, standard monitoring sites, and Stage 1 compliance monitoring sites.
IDSE Guide for Systems Serving < 10,000           5- / 9                               January 2006

-------
       IDSE standard monitoring plans will not be considered confidential business information
       (CBI) and arc subject to the Freedom of Information Act (FO1A). Therefore, your
       distribution system schematic should not contain information that poses a security risk to
       your system.  EPA suggests that you consider one of the following options for submitting
       distribution system schematics:

          •  Option 1: Distribution system schematic with no landmarks or addresses
             indicated.  Show locations of sources, entry points, storage facilities, standard
             monitoring locations, and Stage 1 compliance monitoring locations (required).
             Also include pressure zone boundaries and locations of pump stations.  Provide
             map scale.

          •  Option 2: City map without locations of pipes indicated. Show locations of
             sources, entry points, storage facilities, standard monitoring locations, and Stage 1
             compliance monitoring locations (required). Also include boundaries of the
             distribution system, pressure zone boundaries and locations of pump stations.
             Provide map scale.

       Schematics should be as clear and easy to read as possible.  They should typically be
       submitted on a scale of between 1:4,000 and 1:8,000; however, larger-scale drawings arc
       acceptable as long as systems components can still be clearly shown.  All sizes from 8'/2
       inches x 11 inches to larger, plan-sized sheets arc acceptable.  If electronic versions arc
       submitted, use one of the following file types:

          •  Adobe PDF file (*.pdf)
          •  Microsoft Word (*.doc)
          •  Word Perfect (*. wpd)
          •  Image file (*.gif, *.bmp, *.jpg, *jpcg)

VIII.  Attachments Put a check mark in each of the boxes corresponding to any attachments
       that you have included in your report.

       A distribution system schematic is required. Refer to Section VII for details.

       If you submit your standard monitoring plan electronically, you also have the option to
       submit attachments in hard copy.  Include a note in your electronic  standard monitoring
       plan explaining that attachments  are being submitted in hard copy, and mail the hard
       copy to the IPMC mailing address in your Requirements Summary  Sheet. The IPMC
       will match the hard copy submission with your electronic submission when it is received.

       Enter the total number of pages in your monitoring plan (including  attachments) in the
       blank at the bottom of this section. This will allow EPA or your state to ensure that all
       pages were received.
IDSE Guide for Systems Sewing < 10,000          5-20                                January 2006

-------
Standard Monitoring Plan Form for
Systems Serving < 10,000 page 1 of 5
1. GENERAL INFORMATION
A. PWS Information*
PWSID:
1 B. Date Submitted*

PWS Name:
PWS Address:
City:
State: Zip:
Population Served:

System Type: Source \
D CWS D Subp
D NTNCWS D Grou

C. PWS Operations
Residual Disinfectant Type: D C
Number of Disinfected Sources:

/Vater Type: Buying / Selling Relationships:
art H D Consecutive System
nd n Wholesale System
D Neither

hlorine D Chloramines D Other:
Surface GWUDI Ground Purchased

D. Contact Person*
Name:
Title:
Phone #:
Fax#:
E-mail:

II. IDSE REQUIREMENTS*
A. Number of Sites B. !
Total:
Near Entry Point: D S
Avg Residence Time: D S
High TTHM: n S
High HAAS: D S

Schedule C. Standard Monitoring Frequency
shedule 1 n During peak historical month
chedule 2 (1 monitoring period)
^hedule 3 n Every 90 days (4 monitoring periods)
shedule 4 D Every 60 days (6 monitoring periods)
IDSE Guide jor Systems Serving < 10,000
5-21
Januarv 2006

-------
Standard Monitoring Plan Form for
Systems Serving < 10,000 Page2ofs
III. SELECTING STANDARD MONITORING SITES
A.
eac
B.
moi
Data Evaluated Put a "/" in each box corresponding to the data that you used to select
h type of standard monitoring site. Check all that apply.
Data Type
Type of Site
Near
Entry Pt.
Avg. Residence
Time
High
TTHM
High
HAAS
System Configuration
Pipe layout, locations of storage facilities
Locations of sources and consecutive
system entry points
Pressure zones
Information on population density
Locations of large customers




















Water Quality and Operational Data
Disinfectant residual data
Stage 1 DBP data
Other DBP data
Microbiological monitoring data (e.g., HPC)
Tank level data, pump run times
Customer billing records
























Summary of Data* Provide a summary of data you relied on to justify standard
litoring site selection (attach additional sheets if needed)







IDSE Guide for Systems Serving < 10,000
5-22
January 2006

-------
Standard Monitoring Plan Form for
Systems Serving < 10,000 pagesors
IV. JUSTIFICATION OF STANDARD MONITORING SITES*


Standard
Monitoring
Site ID
(from map)1




Site Type
a Near Entry Pt
LJ Avg. Res. Time
D High TTHM
D High HAAS
D Near Entry Pt
D Avg. Res. Time
D High TTHM
D High HAAS
D Near Entry Pt
D Avg. Res. Time
D High TTHM
G High HAAS
D Near Entry Pt
D Avg. Res. Time
D High TTHM
D High HAAS
Justification




' Verify that site IDs match IDs in Section IV and on your distribution system schematic (See Section
VII of this form).

V. PEAK HISTORICAL MONTH AND STANDARD MONITORING SCHEDULE
A. Peak Historical Month*
B. If Multiple Sources, Source Used to Determine Peak Historical Month
(write "N/A" if only one source in your system)
C. Peak Historical Month Based On* (check all that apply)
D High TTHM D Warmest water temperature
H High HAAS
If you used other information to select your peak historical month, explain here
(attach additional sheets if needed)
IDSE Guide jor Systems Serving < 10.000
5-23
January 2006

-------
Standard Monitoring Plan Form for
Systems Serving < 10,000 pagers
V. PEAK HISTORICAL MONTH AND STANDARD MONITORING SCHEDULE (Continued)
D.
Proposed Standard Monitoring Schedule*
Standard Monitoring
Site ID
(from map) 1




Projected Sampling Date (date or week) 2
Period 1




Period 2




Period 3




Period 4





' Verify that site IDs match IDs in Section IV and on your distribution system schematic (See Section VII of
this form).
' period = monitoring period. Complete for the number of periods from Section II. C. Can list exact date or
week (e.g., week of 7/9/07)
VI. PLANNED STAGE 1 DBPR COMPLIANCE MONITORING SCHEDULE*


Stage 1 DBPR
Monitoring Site ID
(from map) 1




Projected Sampling Date (date or week) 2
Period 1




Period 2




Period 3




Period 4





' Verify that site IDs match IDs on your distribution system schematic (See Section VII of this form).
2 period - monitoring period. Complete for the number of periods in which you must conduct Stage 1 DBPR
monitoring during IDSE monitoring. Can list exact date or week (e.g., week of 7/9/07)
IDSE Guide for Systems Scn'ing < 10,000
5-24
January 2006

-------
  Standard Monitoring Plan  Form for
  Systems Serving < 10,000	   pages of s
  VII.  DISTRIBUTION SYSTEM SCHEMATIC*
  ATTACH a schematic of your distribution system.

   Distribution system schematics are not confidential and should not contain information
   that poses a security risk to your system. EPA recommends that you use one of two
   options:

      Option 1:  Distribution system schematic with no landmarks or addresses
      indicated.  Show locations of sources, entry points, storage facilities, standard
      monitoring locations, and  Stage 1 compliance monitoring locations (required).  Also
      include pressure zone boundaries and locations of pump stations. Provide map
      scale.

      Option 2:  City map without locations of pipes indicated.  Show locations of
      sources, entry points, storage facilities, standard monitoring locations, and Stage 1
      compliance monitoring locations (required). Also  include boundaries of the
      distribution system, pressure zone boundaries and locations of pump stations.
      Provide map scale.
 VIII. ATTACHMENTS
        , i  Distribution System Schematic* (Section VII).

        H  Additional sheets for the summary of data or site justifications (Sections III and IV).

        n  Additional copies of Page 3 for justification of Standard Monitoring Sites (Section
           IV).

        13  Additional sheets for explaining how you used data other than TTHM, HAAS, and
           temperature data to select your peak historical month (Section V).

        n  Additional sheets for planned Stage 1 DBPR compliance monitoring schedule
           (Section VI).

     Total Number of Pages in Your Plan	
Note: Fields with an asterisk (*) are required by the Stage 2 DBPR
IDSE Guide jar Systems Serving < 10.000          5-25                              Januan- 2006

-------
                               This page left intentionally blank.
IDSE Guide for Systems Serving < 10,000           5-26                                   January 2006

-------
 5.2   Conducting Standard Monitoring

       Conducting standard monitoring is an integral part of the IDSE.  The results of standard
 monitoring, along with the results of Stage 1 DBPR compliance monitoring, must be used to
 select the best sites for Stage 2 DBPR compliance monitoring and must be documented in your
 IDSE report. This section presents sampling requirements and tips for sample collection for
 conducting standard monitoring.

       Remember, you must submit your standard monitoring plan before you begin standard
 monitoring. If EPA or your state does not approve or request modifications to your plan, or
 notify you that your plan is still under review within 12 months after the deadline for plan
 submission, you may consider the plan approved. You must conduct standard monitoring
 according to the approved monitoring plan.

 REMINDER: you must continue to collect samples and comply with the Stage 1 DBPR during
 the IDSE. Results  from standard monitoring should not be used for making Stage 1  compliance
 determinations.	

 Your Requirements

       You must conduct standard monitoring according to the schedule and at each of the
 monitoring locations listed in your standard monitoring plan.  If you deviate from the approved
plan for any reason (e.g., a site was not accessible on the planned week and you needed to
 sample during  the next week), you must include an explanation for the deviation in your IDSE
 report.

       During each sampling event, you must collect a dual sample set (i.e., two samples) at
 each location.  One sample must be analyzed for TTHM and the other must be analyzed for
 HAAS. Two samples are required because the analytical methods used for the two groups of
 contaminants require different sample preservation methods. You must use EPA-approved
 methods for analysis of your TTHM and HAAS  samples. More information on EPA-approved
 methods can be found in Appendix C of the IDSE Guidance Manual

 Tips for Sample Collection

       As you  conduct standard monitoring, you should keep in mind the following tips:

       •   Use appropriate sample bottles.  You should use sample bottles that already contain
         the appropriate dechlorinating agent and preservative for sample collection.  You
          should contact your lab for a recommended sampling and preservation protocol. A
         typical sampling protocol can be found in Appendix C of the IDSE Guidance
         Manual.

       •  Flush your sample tap. If you collect samples from a tap, you should open the cold
         water tap and allow the line to flush until the water temperature has stabilized
         (usually  about 3-5 minutes). If you collect a sample at a hydrant or blow-off, the
         flushing  time only needs to be long enough to purge the connecting line to the main.

IDSE Guide for Systems Serving < 10,000          J37                               Januan< 2006

-------
          The purpose of this step is to ensure the sample docs not represent stagnant water that
          has been sitting for a long time in the water line between the street and the faucet.
          The sample should represent the water flowing through the distribution system at the
          chosen sampling point.

       •  Collect cold water samples.  If you collect indoor samples you should collect them
          from a cold water line.

       •  Collect additional water quality data. You may wish to collect additional water
          quality data, such as disinfectant residual and temperature data, at the time of DBF
          sample collection.  This information can be helpful as you interpret standard
          monitoring results  (e.g., unusually low residual at a location could mean unusually
          high residence time).

       •  Re-sample if a sample is lost or broken. If a sample bottle is lost or broken after
          sample collection,  you should re-sample as soon as possible after the loss occurs.
          Only the lost sample needs to be recollected, not the entire sample set that was
          collected together.  Make sure to note the loss of sample and resample date  as a
          deviation in your 1DSE report.

       If you need to change an IDSE standard monitoring sampling  location for reasons beyond
your control, or if you miss a required sampling period entirely, you should contact EPA or your
state so they can approve your re-sampling strategy.
5.3    Selecting Stage 2 DBPR Compliance Monitoring Sites and Preparing the
       IDSE Report

       Every system that conducts standard monitoring must use results from Stage 1  DBPR
compliance monitoring and standard monitoring to select Stage 2 DBPR compliance monitoring
sites.  You must include your monitoring results and recommended Stage 2 compliance
monitoring sites in an IDSE Report.  You should submit your IDSE report to the Information
Processing and Management Center (IPMC) for review by EPA or your state. See Section 1.3 of
this guidance manual for information on how to submit your plan to the IPMC.

       This section presents the required protocol for selecting Stage 2 DBPR compliance
monitoring sites and provides guidance for preparing an IDSE report.

       EPA has developed a Form for the IDSE Report for Standard Monitoring for
Systems Serving < 10,000, presented in Section 5.3.3 and available electronically as part of the
IDSE Tool.  You are not required to use this form; however, if you choose not to
use it, refer to Exhibit 5.6 for a list of the minimum elements you must include in
your IDSE report. Examples of completed reports can be found in Appendix B of
this gude and in the IDSE Guidance Manual. The IDSE Tool is available on
EPA's website at http://www.epa.gov/sarewaler/disinrcctioii/stage2.                 IQ$£ jool
IDSE Guide for Systems Serving < 10,000          5-28                                January 2006

-------
    Exhibit 5.6  Required Elements of Your IDSE Report for Standard Monitoring

        •  Explanation of any deviations from approved standard monitoring plan
        •  TTHM and 1IAA5 analytical results from Stage 1 DBPR monitoring and IDSE
           standard monitoring
        •  Recommendations and justification of Stage 2 DBPR monitoring sites and
           sampling dates
        •  If changed from the approved standard monitoring plan:
              Distribution system schematic
              Population served by the system
              System type (subpart H or ground water)
5.3.1   Selecting Stage 2 DBPR Compliance Monitoring Locations

       All systems serving < 10,000 people must select one highest TTHM and one highest
HAAS site for Stage 2 DBPR compliance monitoring. Some small systems may be able to use
one location as both their highest TTHM and highest HAAS site if their highest concentrations
occur at the same location and during the same month.  Sec page 2 of the Standard Monitoring
Requirements - Attachment sheet in Chapter 2 for more information.

       The required procedure for selecting Stage 2 compliance monitoring locations is laid out
in the Stage 2 rule and summarized below.

Step I: Calculate TTHMancllIAAS LRAA for each site

       You should begin the Stage 2 site selection process by calculating the locational running
annual average (LRAA) for cach'standard monitoring site and Stage  1 DBPR compliance
monitoring site. Note that because the duration for IDSE standard monitoring is one year, the
LRAA for each standard monitoring site is equivalent to the average of all TTHM or HAAS data
collected at the location (either one or four   1=_________=___________==^
points depending on your IDSE standard
                                          For systems collecting quarterly data:
                                          LRAA = (Ql + Q2+ Q3 + Q4) / 4

                                          For systems collecting annual data (once /
                                          year):
                                          LRAA = result for warmest temperature month
monitoring frequency). The LRAA for
each Stage 1 DBPR compliance
monitoring site should be the LRAA for
the year that you conducted standard
monitoring (either one or four data points
depending on your Stage  1 compliance
monitoring frequency). You should
consider using a spreadsheet to store your
data and calculate your LRAAs.

Step 2: Select Stage 2 sites based on LRAA 's

       Next, select your Stage 2 DBPR compliance monitoring sites based on your LRAA
results:
IDSE Guide for Systems Serving < 10,000           5-29                              January 2006

-------
       •  Select the site with tlie highest TTI1M LRAA as your Highest TTHM site.

       •  Select the site with the highest HAA5 LRAA as your Highest HAAS site.

If the highest HAAS LRAA occurs at the same location and during the same month as the
highest TTHM LRAA, you may be able to use the same site to represent both your Highest
TTHM and Highest HAAS site if you meet other criteria. See page 2 of the Standard
Monitoring Requirements - Attachment sheet in Chapter 2 for more information.

Do I alwa\'S need to follow the protocol for selecting Stage 2 DBPR compliance monitoring
sites?

       No, as long as you justify your site selection. Although sites should generally be
selected using highest LRAAs, it is possible that slight differences between two LRAAs might
not be as important as other factors for selecting sites. Other reasons that can be used to a site
that is not the highest LRAA include:

       •  The site provides more complete geographic coverage of the entire distribution
          system

       •  The site allows you to maintain a historical record

       •  Sampling at that site provides the opportunity to collect other water quality or
          operational data (e.g., chloraminc systems may want to collect nitrate or nitrite data at
          that site)

       It is possible that EPA or your state may not concur with your justification and may
require you to select different Stage 2 compliance monitoring sites.
5.3.2   Determining Your Stage 2 DBPR Compliance Monitoring Schedule

       The first step in determining your Stage 2 DBPR compliance monitoring schedule is to
select your peak historical month. You should use the peak historical month selected in your
IDSE standard monitoring plan unless new data suggest another month.  Refer to Section 5.1.2
for more information on determining peak historical month.

       You must conduct Stage 2 DBPR compliance monitoring during the peak historical
month.  If you are a subpart H system that serves more than 499 people, you must also conduct
Stage 2 compliance sampling at 90 day intervals before and/or after the peak historical month.

       The intent of the required time interval is to ensure that samples are representative of the
quality of water over an extended period and do not over-emphasize either high or low
concentrations of TTHM or HAAS that might occur seasonally.  For example, a system on
quarterly monitoring could sample in the third full week of every third month.  It is not
necessary to sample all sites on the same day.
IDSE Guide for Systems Serving < 10,000          5-30                               January 2006

-------
 5.3.3  Preparing the IDSE Report for Standard Monitoring

       Every system that conducts IDSE standard monitoring must prepare and submit an IDSE
 Report for Standard Monitoring. You should submit the report to the Information Processing and
 Management Center (IPMC) for review by EPA or your state. See Section 1.3 of this guidance
 manual for information on how to submit your report to the IPMC.

       EPA has developed a Form for the IDSE Report for Standard Monitoring For
 Systems Serving < 10,000, presented in this section and available electronically as part of the
 IDSE Tool.  You are not required to use this form; however, if you choose not to use it, refer to
 Exhibit 5.6 for a list of the minimum elements you must include in your IDSE report.
       The IDSE Tool creates a custom form for your system and provides links
to technical guidance from this manual. The tool is available on EPA's website at
http://www.epa.gov safcwalcr disin(cctioiv'stagc2.                                !DSE Tool
       Before you begin Stage 2 DBPR compliance monitoring, you will also be required to
prepare a Stage 2 DBPR compliance monitoring plan. In addition, if you are a subpart H system
serving > 3,300 people, you must submit a copy of your Stage 2 compliance monitoring plan to
the state. If you include compliance calculation procedures in your IDSE report, the report can
meet the requirement of the plan, and you do not have to prepare or submit a separate plan. As a
guide for specifying your compliance calculation procedures, refer to the Stage 1 DBPR,
141.133(b), and your Stage 1 compliance monitoring plan.  Check with your state, as they may
have different requirements under the Stage 2 DBPR. If you arc a consecutive or wholesale
system, your state may choose to use its special primacy authority to modify your Stage 2
compliance monitoring requirements. In this case, you should check with the state to sec if they
arc going to use this authority. You should develop your IDSE report for the total number of
required Stage 2 compliance locations for your system.

       The IDSE report for standard monitoring form includes the following sections:

       I.     General Information
       II.     Stage 2 DBPR Requirements
       III.    Monitoring Results
       IV.    Justification of Stage 2 DBPR Compliance Monitoring Sites
       V.     Peak Historical Month and Stage 2 DBPR Compliance Monitoring Schedule
       VI.    Distribution System Schematic
       VII.   Attachments

Sections of the form with an asterisk (*) are required by the Stage 2 DBPR. Examples of
completed IDSE reports are in Appendix B of this manual and in the IDSE Guidance Manual.
The rest of this section provides guidance on the completion of this form.
IDSE Guide for Systems Sewing < 10,000          5-31                               Januaiy 2006

-------
I.      General Information

       I-A.   P WS I n formati on * - If nothing has changed since you completed your standard
             monitoring plan form, copy information from your plan into this section. If your
             system characteristics have changed, sec Section 5.1.3 of this manual for
             guidance on completing this section.

       I.E.   Date Submitted* - Enter either the date that you are submitting the form
             electronically, putting it in the mailbox, or dropping it off with an express
             delivery service. Be sure to submit your IDSE report before the deadline found
             on your requirements summary sheet.

       I.C.   PWS Operations - This section asks questions about your system to help inform
             EPA and state personnel during the plan review process.  If nothing has changed
             since you completed your standard monitoring plan form, copy information from
             your plan into this section. If your system characteristics have changed, see
             Section 5.1.3 of this manual for guidance on completing this section.

       I.D.   Contact Person* - Enter the contact information of the person who is submitting
             the report.  This should be the person who will be available to answer questions
             from EPA and/or state reviewers.

II.     Stage 2 DBPR Requirements*

       II.A   Number of Compliance Monitoring Sites - If you serve fewer than 10,000 people,
             you need one highest TTHM and one highest HAAS site.

       II.B.   Schedule - This should be the same schedule you entered for your standard
             monitoring plan. See  Section 5.1.3 of this manual for guidance.

       II.C.   Compliance Monitoring Frequency - If you are a subpart H system serving < 500
             people or a ground water  system serving < 10,000 people, you must monitor once
             per year during the peak historical month. If you are a subpart H system that
             serves between 499 and 10,000 people, you must conduct Stage 2 compliance
             monitoring at 90 day intervals before and/or after the peak historical month.

III.    Monitoring Results*

       III.A. Did you deviate in any way from your approved standard monitoring plan? -  Put a
             check mark in the appropriate box to identify whether your system collected  any
             standard monitoring samples on different dates or at different locations than
             indicated in your approved standard monitoring plan.

             If you sampled on a different date or during a different week than scheduled in the
             approved monitoring plan, you should write an explanation in the space provided
             (or in attached sheets). You should include the standard monitoring site ID, the
             scheduled sampling date or week from your monitoring plan, and the actual

IDSE Guide jor Systems Serving < 10,000           5-32                                January 2006

-------
              sampling date.  You must also explain why you sampled on a different day or
              week than planned.  An example explanation is shown below.

                    According to our standard monitoring plan, we were to collect samples at
                    standard monitoring sites 2 and 4 on January 14, 2009. However, a
                    major snowstorm created hazardous road conditions and limited our
                    access to sample locations. Therefore, we conducted our sampling at all
                    sites on Januan- 18, 2009 after the roads were cleared.

       III.B.  Where were your TTHM and HAAS samples analyzed? - Put a check mark in the
              appropriate box to identify whether your system analyzed TTHM and HAAS
              samples in an in-house laboratory or sent the samples to a certified laboratory for
              analysis.

              If you analyzed your TTHM and HAAS samples in an in-house laboratory, check
              the appropriate box to identify whether your laboratory is certified. If you  sent
              your TTHM and HAAS samples to a certified laboratory, enter the name of the
              laboratory in the blank.  If you used more than one laboratory (e.g., if you used
              different laboratories for standard monitoring samples and Stage 1 DBPR
              compliance samples), list both laboratories, or check "in-house" and list the name
              of the laboratory if applicable.

       III.C   What method was used to analyze your TTHM and HAAS samples'? Put a  check
              mark in the appropriate box to indicate the analytical method used to measure the
              TTHM and HAAS concentrations of your standard monitoring and Stage 1  DBPR
              compliance samples.  If more than one method was used (e.g., if you used
              different  laboratories for standard monitoring samples and Stage 1 DBPR
              compliance samples), check more than one method. If you do not know what
              method was used, contact your laboratory.

       II1.D.  Standard Monitoring and Stage 1 Compliance Monitoring Results - TTHM -
              Enter your TTHM results for each standard monitoring site and each Stage 1
              DBPR compliance monitoring site for each monitoring period in which you
              collected data (as laid out in your standard monitoring plan).  For each sample
              result, enter the date on which sampling was conducted.

       III.E.   Standard Monitoring and Stage 1 Compliance Monitoring Results - HAAS  - Enter
              your HAAS results for each standard monitoring site and each Stage 1 compliance
              monitoring site for each monitoring period in which you collected data (as laid
              out in your standard monitoring plan).  For each sample result, enter the date on
              which sampling was conducted.

IV.    Justification of Stage 2 DBPR Compliance Monitoring Sites*

          Enter the site ID from the distribution schematic and the site type (whether it is
          highest TTHM or highest HAAS). For example:
1DSE Guide jor Systems Serving < 10,000          5-33                               Januaiy 2006

-------
              77//A site had the highest ITU MLR A A

          An example of how you might justify a site that was not selected using the protocol is
          below:

             Among the three remaining high TTHM sites, standard monitoring Site 1 has the
             highest TTHMLRAA. However, Stage 1 DBPR Site 2 has only a slightly lower
              TTHMLRAA than standard monitoring Site 1.  Therefore, we choose Stage 1
             DBPR Site 2 over standard monitoring Site 1 to maintain the historical DBF
             record.

V.     Peak Historical Month and Stage 2 DBPR Compliance Monitoring Dates

       V.A.  Peak Historical Month* - Enter the month that you determined to be your peak
             historical month.

       V.B   Is Your Peak Historical  Month the Same as in Your IDSE Standard Monitoring
             Plan? - Put a check mark in the appropriate box to identify whether your system
             used the same peak historical month as in your standard monitoring plan. If your
             standard monitoring results prompted you to change your peak historical month,
             explain how you selected a new peak historical month.

       V.C.  Proposed Stage 2 DBPR Compliance Monitoring Schedule* - Enter the ID for
             each Stage 2 DBPR compliance monitoring site in the table (these should match
             the ID's you enter in Section IV and on your schematic). Enter your proposed
             sampling schedule for the number of monitoring periods identified in Section
             II.C. The entry can be a specific date or week and can be in a number of different
             formats. For example:

                    7/9/07
                    2nd week in Nov  '07
                   Week of 7/9/07

             Remember that at least one monitoring period must be during the peak historical
             month identified in Section V.A.

VI.    Distribution System Schematic* - A distribution system schematic is required only if it
       has changed from your approved IDSE standard monitoring plan. If it has changed,
       attach the revised  distribution system schematic. See Section 5.1.3 of this manual for
       guidance.

VII.   Attachments - Put a check mark in each of the boxes corresponding to any attachments
       that you have included in your report.

       A distribution system schematic is required only if it has changed since you submitted
       your IDSE standard monitoring plan. Refer to Section VI for details.
IDSE Guide for Systems Serving < 10,000          5-34                               January 2006

-------
       If you submit your 1DSE report electronically, you also have the option to submit
       attachments in hard copy. Include a note in your electronic 1DSE report explaining that
       attachments arc being submitted in hard copy, and mail the hard copy to the IPMC
       mailing address in your Requirements Summary Sheet. The IPMC will match the hard
       copy submission with your electronic submission when it is received.

       If you arc a subpart H system serving >3,300 people, you must submit a copy of your
       Stage 2 compliance monitoring plan to the state. If you include compliance calculation
       procedures in your IDSE report, the report can meet the requirement of the plan, and you
       do not have to prepare or submit a separate plan. As a guide for specifying your
       compliance calculation procedures, refer to the Stage 1 DBPR, 141.133(b), and your
       Stage 1 compliance monitoring plan. Check with your state, as they may have different
       requirements under the Stage 2 DBPR.

       Enter the total number of pages in your IDSE report (including attachments) in the blank
       at the bottom of this section. This will allow EPA or your state to ensure that all pages
       were received.
IDSE GuideJor Systems Serving < 10.000          5-35                               January 2006

-------
                               This page intentionally left blank.
IDSE Guide for Systems Serving < 10,000            5-36                                   Januaiy 2006

-------
IDSE Report for Standard Monitoring for
Systems Serving < 1 0,000 Page 1 of e
I. GENERAL INFORMATION
A. PWS Information*
PWSID:

B. Date Submitted*

PWS Name:
PWS Address:
City:
Population Served
State: Zip:


System Type: Source Water Type:
D CWS D
D NTNCWS D
Subpart H
Ground

C. PWS Operations
Residual Disinfectant Type:


Buying / Selling Relationships:
n Consecutive System
D Wholesale System
D Neither

T Chlorine D Chloramines D Other:
Number of Disinfected Sources: Surface


GWUDI Ground Purchased

D. Contact Person*
Name:
Title:
Phone #:

Fax#:
E-mail:

II. STAGE 2 DBPR REQUIREMENTS*
A. Number of
Compliance Monitoring
Sites
Highest TTHM: 1
Highest HAAS: 1
Total: 2

B. Schedule C
n Schedule 1
D Schedule 2
D Schedule 3
D Schedule 4
. Compliance Monitoring Frequency
D During peak historical month
(1 monitoring period)
13 Every 90 days (4 monitoring periods)
IDSE Guide for Systems Serving < J0,000
5-37
January 2006

-------
 IDSE Report for Standard Monitoring for
 Systems Serving < 10,000	                          Page 2 of e
 III. MONITORING RESULTS*
 A.   Did you deviate in any way from your approved standard    D Yes    a No
      monitoring plan?
      If YES, explain (attach additional pages if necessary):
 B.  Where were your TTHM and HAAS samples analyzed?
      D In-House
           Is your in-house laboratory certified?                 n Yes    D No
      D Certified Laboratory
     Name of certified laboratory:
 C.  What method(s) was used to analyze your TTHM and HAAS
     samples?
       TTHM                          HAAS
     D EPA 502.2                    H EPA 552.1
     D EPA 524.3                    D EPA 552.2
     D EPA 551.1                    n EPA 552.3
                                   D SM 6251 B
IDSE Guide for Systems Serving < 10,000         5-38                           January 2006

-------
IDSE Report for Standard Monitoring for
Systems Serving < 1 0,000 page 3 of 6
III. MONITORING RESULTS (Continued)*
D. 5
Standard Monitoring and Stage 1 Compliance Monitoring Results - TTHM
Site ID1










Data Type
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
TTHM (mg/L)
















































































LRAA




















1 Verify that site IDs for IDSE standard monitoring sites match the site IDs in your
Standard Monitoring Plan.
Attach additional sheets as needed.

IDSE Guide for Systems Serving < 10,000
5-39
Januarv 2006

-------
IDSE Report for Standard Monitoring for
Systems Serving < 1 0,000 page 4 of e
III. MONITORING RESULTS (Continued)*
E. S
Standard Monitoring and Stage 1 Compliance Monitoring Results - HAAS
Site ID1










Data Type
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
HAAS (mg/L)
















































































LRAA




















1 Verify that site IDs for IDSE standard monitoring sites match the site IDs in your
Standard Monitoring Plan.
Attach additional sheets as needed.

IDSE Guide for Systems Sewing < 10.000
5-40
January 2006

-------
IDSE Report for Standard
Systems Serving < 10,000
IV.





Monitoring for
Page 5 of 6
JUSTIFICATION OF STAGE 2 DBPR COMPLIANCE MONITORING SITES*

Stage 2
Compliance
Monitoring
Site ID




Site Type
::i Highest TTHM
U Highest HAAS
G Highest TTHM
'.:, Highest HAAS


Justification




V. PEAK HISTORICAL MONTH AND PROPOSED STAGE 2 COMPLIANCE MONITORING
SCHEDULE
A.
B.
C.
Peak Historical Month*
Is Your Peak Historical Month the Same as in Your Standard Monitoring
Plan?
D Yes 3 No
If no, explain how you selected your new peak historical month (attach
additional sheets if needed):













Proposed Stage 2 DBPR Compliance Monitoring Schedule*
Stage 2 Projected Sampling Date (date or week)1
Compliance
Monitoring
Site ID
Period 1


1 period = monitoring period. Complete
Section 1 1.C,
Period 2 Period 3 Period 4


for the number of monitoring periods from


IDSE Guide jor Systems Serving < JO, 000
5-41
January 2006

-------
 IDSE Report for Standard Monitoring for
 Systems Serving < 10,000                                  Page e of e
 VI. DISTRIBUTION SYSTEM SCHEMATIC*
 ATTACH a schematic of your distribution system if it has changed since you submitted
 your Standard Monitoring Plan.
 VII. ATTACHMENTS
     D  Additional sheets for explaining how and why you deviated from your standard
        monitoring plan (Section III).

     D  Additional sheets for Standard Monitoring and Stage 1 DBPR monitoring results
        (Section III).

     D  Additional sheets for explaining how you selected the peak historical month (Section
        V).

     D  Distribution system schematic* (Section VI). REQUIRED if it has changed from
        your approved IDSE standard monitoring plan.

     D  Compliance calculation procedures (for Stage 2 Compliance Monitoring Plan)


 Total Number of Pages in Your Report:	
Note:  Fields with an asterisk (*) are required by the Stage 2 DBPR
IDSE Guide for Systems Serving < 10,000         5-42                             January 2006

-------
 5.4    Recordkeeping

       The IDSE standard monitoring report must be kept on file
 for 10 years after the date it is submitted.  If EPA or your state
 modifies the recommendations made in your report or approves
 alternative Stage 2 DBI'R compliance monitoring locations, you
 must also keep a copy of EPA or your state's notification on file
 for 10 years after the date of the notification. You must make
 your IDSE report and any notification available for review by
 your state or the public.

       The standard monitoring plan, including any modifications
 by EPA or your state, must also be kept on file for as long as you
 are required to retain your IDSE standard monitoring report. You
 must make the plan and any  modifications available for review by
 your state or the public.
5.5    Next Steps: Preparing the Stage 2 DBPR Compliance Monitoring Plan

       As the final step before you can begin compliance monitoring for the Stage 2 DBPR, you
must develop and implement a Stage 2 DBPR monitoring plan by the deadline provided in
your requirements summary sheet. The plan will be similar to your Stage 1  DBPR monitoring
plan in that it will identify how you intend to sample for compliance with Stage 2.  You must
keep your plan on file for state and public review. If you arc a Subpart H system serving >
3,300 people, you must submit your plan to EPA or your state prior to when you are required to
start monitoring.

       Exhibit 5.7 contains the minimum requirements for what must be included in your
Stage 2 DBPR compliance monitoring plan. Because compliance monitoring plans arc not
addressed as part of the IDSE provisions of the Stage 2 DBPR, EPA has not included detailed
guidance far developing Stage 2 compliance monitoring plans in this guidance manual.
EPA plans to develop other manuals and training that address the compliance monitoring
provisions of the Stage 2 DBPR.
See EPA's website http:'7ww\v.epa.gov/safewatcr/disinfection/stage2 for a up-to-date
inventory of Stage 2 DBPR guidance manuals and training materials, or call the Safe Drinking
Water Hotline at 1 -800-426-4791.
IDSE Guide for Systems Serving < 10,000
5-43
January 2006

-------
  Exhibit 5.7  Required Contents of Stage 2 DBPR Compliance Monitoring Plans
            AH Systems
Additional Requirements for Consecutive and
            Wholesale Systems '
     Monitoring locations
     Monitoring dates
     Compliance calculation
     procedures
 If your state has used its special primacy
 authority to modify your monitoring
 requirements, you must include monitoring plans
 for other systems in your combined distribution
 system
1. See Appendix A of this manual for guidance specifically for consecutive and wholesale systems
IDSE Guide for Systems Serving < 10,000
   5-44
January 2006

-------
             Appendix A



Consecutive and Wholesale System Issues

-------
This page intentionally left blank.

-------
 A.I   Introduction

       If your system is part of a combined distribution system, your compliance schedule for
 the IDSE is based on the population served by the largest system in your combined distribution
 system.  It is important that all systems in a combined distribution system conduct an IDSE at the
 same lime  so that all systems in that combined distribution system know their relative DBF
 concentrations and can make the necessary treatment and/or operational changes before Stage 2
 compliance begins.

       The following questions and answers are provided to help you determine if you are in a
 combined distribution system and what this means with respect to your IDSE schedule.

 What is a combined distribution system?

       The Stage 2 DBPR rule defines combined distribution system, wholesale system, and
 consecutive system as follows:

       •   A combined distribution system is the interconnected distribution system consisting
           of the distribution systems of wholesale systems and of the consecutive systems that
           receive finished water.

       •   A wholesale system is a public water system that treats source water as necessary to
           produce finished water and then delivers some or all of that finished water to another
           public water system. Delivery may be through a direct connection or through the
           distribution system of one or more consecutive systems.

       •   A consecutive system is a public water system that receives some or all of its finished
           water from one or more wholesale systems. Delivery may be through a direct
           connection or through the distribution system of one or more consecutive systems.

       In Example A.I, where system C buys water from system B who buys water from
 systems A and D, all four systems are considered to be in the same combined distribution
 system. Even if systems A and D never exchange water, they are still considered to be part of
 the same combined system.
IDSE Guide for Systems Serving < 10,000           A-l                                January 2006

-------
             Example A.1 Example of a Combined Distribution System
                                                  Treatment
                                                    Rant
                                                              Wholesale System
                                                                   I
        Treatment
          Rant
                     Wiolesale System
                          I
Consecutive System
      i
Consecutive System

  J.
  >* SystemC'
                                      Combined Distribution
                                          System

       If you receive water from a wholesale system only on an emergency basis or receive only
a small percentage and small volume of water from a wholesale system, your state may have
excluded you from the combined distribution system. If you deliver water to a consecutive
system only on an emergency basis or deliver only a small percentage and small volume of water
to a consecutive system, your state may also have excluded you from the combined distribution
system. You should receive a letter from EPA or your state that tells you the schedule that was
determined for your system by your state. Sec Section 2.2 for more information.
How do I know if I am a S
                              H or a ground water system?

       If you treat or deliver surface water or ground water under the direct influence of surface
water (GWUDI) as any part of your supply, you are considered a subpart H system. If you treat
or deliver only ground water, you are considered a ground water system. If you treat or deliver a
combination of the two, you are considered a subpart H system.  If you do not treat your own
water and you do not know whether you receive surface water, GWUDI, or ground water, you
should consult with your state to determine what your IDSE and Stage 2 compliance monitoring
requirements are.

If I'm in a combined distribution system, which of my IDSE requirements are based on the
population of the largest system in my combined distribution system?

       If you are part of a combined distribution system, only your compliance schedule is
based on the population of the largest system in your combined distribution system. Other
requirements are based on your retail population and source water type. The largest system may
be a wholesale system or a consecutive system.
IDSE Guide for Systems Serving < 10,000
                                          A-2
                                 Januarv 2006

-------
If I'm in a combined distribution system, which of my IDSE requirements are based on my
individual system's population?

        If you arc in a combined distribution system, the number of samples that you must collect
and the frequency at which you must monitor for both the IDSE and Stage 2 DBPR monitoring
are based on your individual system's population.

If I'm in a combined distribution system, when do I submit my 40/30 Certification?

       If you are part of a combined distribution system and want to submit a 40/30
certification, submit your request based on the schedule of the largest system in your combined
distribution system using the information in the table below.
Population Served by the Largest System
in the Combined Distribution System
Systems serving 1 00,000 people
Systems serving 50,000-99,999 people
Systems serving 10.000-49,999 people
Systems serving < 10,000 people
40/30 Certification Deadline
October 1,2006
April 1,2007
Oetober 1 , 2007
April 1,2008
How does my standard monitoring schedule change if I'm in a combined distribution system?

       If you arc part of a combined distribution system and plan to conduct standard
monitoring or an SSS, your schedule for conducting activities associated with these IDSE
options is based on the population of the largest system within your combined distribution
system. You can use the table below to help identify the appropriate schedule for your system
for submitting your monitoring plan, performing IDSE monitoring, and submitting your report.
Population Served by
the Largest System in
the Combined
Distribution System
> 100,000 people
50,000-99,999 people
10.000-49.999 people
< 10.000 people
You Must Submit Your
Standard Monitoring
Plan to the State By '
October 1,2006
April 1,2007
October 1,2007
April 1,2008
You Should Complete
Any Monitoring By
September 30, 2008
March 3 1,2009
September 30, 2009
March 3 1,20 10
You Must Complete
Your IDSE Report
By2
January 1,2009
July 1,2009
January 1,2010
July 1,2010
11f the state does not approve or modify your plan within 12 months after the date identified in this column, you may
consider the plan that you submitted as approved and must implement that plan so that you complete standard
monitoring no later than the date identified in the third column.
2 If the state does not approve or modify your report within three months after the date identified in this column (six
months after the date identified in this column if you must comply on the schedule of systems serving 10,000 to
49,999), you may consider the report that you submitted as approved and must implement the recommended Stage 2
compliance monitoring.
IDSE Guide for Systems Serving < ]0,000
A-3
January 2006

-------
What else should 1 do if I'm in a combined distribution system?

       It is very important that you start communicating with the other systems within your
combined distribution system to share data and information. You should copy other systems
within your combined distribution system on correspondence you submit to the EPA or your
state as part of the IDSE process. If you are unsure of what other systems are within your
combined distribution system and how to contact these systems, your state drinking water
program may be able to provide contact information.

Can my combined distribution system be considered one system for the purposes of the IDSE?

       No, each individual system must conduct its own IDSE.  The schedule for your IDSE
must be based on the population of the largest system in the combined distribution system. The
rest of your IDSE requirements are based on your individual system's population.  You cannot
conduct one IDSE for the entire combined distribution system.

Can my combined distribution system be considered one system for the purposes of Stage 2
compliance monitoring?

       If your state chooses  to use its authority to treat your combined distribution system as one
system for Stage 2 DBPR compliance monitoring, the minimum number of Stage 2 DBPR
monitoring sites and monitoring frequency for the combined distribution system will be based on
the total population and nature of the interconnection of the combined distribution system. Each
consecutive or wholesale system must have at least one Stage 2 compliance monitoring location.
Remember this will only happen if the state allows this option. Consequently, you should
develop your IDSE report for the total number of required Stage 2 compliance locations for your
system unless you hear otherwise from your state.
A.2    Communication Between Wholesale and Consecutive Systems

       As discussed in Section A. 1, the Stage 2 DBPR requires consecutive and wholesale
systems to conduct an IDSE at the same time as the largest system in the combined distribution
system. Note that in some cases, this may not be the wholesale provider.  This section discusses
recommended approaches for communication between consecutive and wholesale systems when
completing an IDSE.

       Consecutive systems are encouraged to contact their wholesale provider as soon as is
reasonably possible after promulgation of the Stage 2 DBPR to determine what plans, if any, the
wholesale system has already made regarding the IDSE. Keep in mind that, while it is
recommended, it is not the responsibility of the wholesale system to contact the consecutive
system regarding the IDSE. Consecutive systems are encouraged to reach out to the wholesale
systems to make the initial contact regarding the IDSE. When a consecutive system receives
water from another consecutive system, communication should involve all three parties, i.e., both
consecutive systems and the wholesale system.  At a minimum, you should discuss the following
questions during this initial contact:
IDSE Guide for Systems Serving < 10,000          A-4                               January 2006

-------
        1.  When arc our (both the wholesale and consecutive system) IDSE plans due?
       2.  When are our IDSE reports due?
       3.  What type of IDSE does the wholesale system intend to complete (Standard
           Monitoring Program or System Specific Study)? Note: Systems are not required to
           choose the same IDSE option
       4.  At what stage in IDSE planning is the wholesale system?
       5.  During what  month(s) docs the wholesale system intend to conduct DBF monitoring?
       6.  Does the wholesale system have water quality data (e.g., temperature, DBF data,
           source water  quality data, operational data, which wholesale sources serve which
           consecutive systems and when) that might help the consecutive system prepare their
           IDSE plan?
       7.  Would the wholesale system be willing to exchange copies of draft IDSE plans with
           the consecutive system?

       Consecutive systems can consider but are not required to select the same peak historical
month as the wholesale system. The peak historical month for a consecutive system that has
another source(s) may actually be in a different month than the month selected by the wholesale
system. If a consecutive system that has no other sources and that has limited data from which to
make a decision, they could reasonably assume that its peak historical month is the same as the
month selected by the wholesale system.

       Consecutive systems should attempt to coordinate their IDSE  monitoring with that of the
wholesale system. Coordinating IDSE monitoring schedules will allow the two (or more)
systems to better utilize data from the  IDSE monitoring period to formulate a Stage 2 DBPR
compliance strategy, if necessary. Additionally, there may  be some benefit in trying to better
understand how DBF formation occurs throughout the combined distribution system, especially
if DBF levels arc relatively high.

       Where it is not possible to coordinate IDSE monitoring, consecutive systems are still
encouraged to work  with their wholesale system to coordinate their proposed Stage 2 DBPR
compliance monitoring schedules that must be included in the final IDSE report. Draft and final
copies of the IDSE plans for the consecutive system and the wholesale system  should be shared
between the systems. Where a consecutive  system receives water through another consecutive
system, all three (or  more) systems should share their IDSE plans. This information can be used
to verify that water quality and water age throughout the combined distribution system is
represented through  the monitoring plans. For example, if you have multiple entry points from
the same wholesaler, they may have a  storage tank prior to one entry point to your system but no
storage tank prior to another entry point. In this case, you would want to select the site after the
tank that is more likely to have high water age as a monitoring location for your standard
monitoring plan.

       As IDSE monitoring progresses, consecutive and wholesale systems are encouraged to
share monitoring results.  When such an approach is utilized, results can be compared for
consistency and to help identify potential compliance issues related to the Stage 2 DBPR.

       A copy of each system's IDSE report should be shared with the other system(s). It is not
necessary for multiple consecutive systems within a combined distribution system to share their

IDSE Guide for Systems Serving < 10.000           T~5                                January 2006

-------
reports, unless one of those systems provides water to another consecutive system, but it is
recommended that the wholesaler provide a copy of its report to each consecutive system, and
each consecutive system provide a copy of its report to the wholesale system. This will help
consecutive systems to determine which compliance strategies, if necessary, arc feasible for
them. It will also help the wholesale system to understand DBF formation in the finished water.

       Upon completion of the IDSE, it is recommended that consecutive and wholesale systems
work together to discuss their Stage 2 DBPR compliance monitoring schedules for the IDSE
report. As with IDSE monitoring, there may be some benefit in coordinating Stage 2
monitoring. Consecutive systems may want to contract with their wholesale system, or contract
together with  the same laboratory to coordinate Stage 2 compliance monitoring. If consecutive
and wholesale systems have the same peak historical month, they may wish to take their samples
at approximately the same time during the peak month. Observing  DBF formation throughout
the combined distribution system using Stage 2 compliance monitoring data can help to identify
possible solutions to compliance-related issues.

       More information on communication between consecutive and wholesale systems can be
found in EPA's Stage 2 DBPR Consecutive Systems Guidance Manual.
A.3   Understanding DBF Formation in Combined Distribution Systems

       The IDSE will help consecutive and wholesale systems to better understand DBF
formation in their systems. Since the Stage 1  DBPR did not explicitly address consecutive
systems, the IDSE may provide Ihc first opportunity for some consecutive systems to acquire
comprehensive information about DBP levels in their distribution system. As discussed above,
consecutive and wholesale systems should  consider coordinating their IDSE sampling schedules
to facilitate a better understanding of DBP formation across the combined distribution system.
Wholesale and consecutive systems should also consider exchanging any existing monitoring
data, particularly any DBP data collected by the wholesale system in the consecutive system.
This data may be helpful to both systems in understanding DBP formation in the combined
distribution system and may help the consecutive system in choosing monitoring locations for
the IDSE.

       DBP formation typically increases with water age. Wholesale and consecutive systems
can make a relative estimate of water age by looking at the extent of their wholesale and
consecutive distribution systems, and the distribution of customers.  DBP sampling at the entry
point as part of the IDSE can help consecutive systems understand whether DBP formation is
occurring primarily in the wholesale system or the consecutive system.  This can help systems to
focus control strategies on the wholesale system, the consecutive system, or a combination of the
two. Information on reducing DBP levels in consecutive systems and discussing compliance
strategies with wholesale systems can be found in EPA's Stage 2 DBPR Consecutive Systems
Guidance Manual.
IDSE Guide for Systems Serving < 10,000           A-6                                January 2006

-------
                                 Appendix B

         Example IDSE Standard Monitoring Plan and Report for
              a Surface Water System Serving 6,000 People
      This appendix provides an example IDSE standard monitoring plan and report for a
surface water system serving 6,000 people and choosing to complete standard monitoring. For
this example, the state did not require any modifications to the study plan.

      Chapter 5 discusses the standard monitoring plan, conducting standard monitoring,
selection of Stage 2 DBPR sites, and preparing the standard monitoring report. The application
of the basic guidance on standard monitoring location selection and Stage 2 DBPR compliance
monitoring location selection is shown in this example.

-------
This page intentionally left blank.

-------
Standard Monitoring Plan Form for
Systems Serving < 1 0,000 page 1 of 5
1. GENERAL INFORMATION
A. PWS Information*
PWSID: US1111111
B. Date Submitted* March 17.
2008

PWS Name: ElmCty
PWS Address: 1234 Main Street
City: Elm City State: US Zip: 99999
Population Served: 6,000

System Type:
BCWS
D NTNCWS


Source Water Type:
B Subpart H
D Ground

C. PWS Operations
Residual Disinfectant Type: E Chlorine n Ch
Number of Disinfected Sources: 1 Surface



Buying / Selling Relationships:
D Consecutive System
D Wholesale System
H Neither

loramines D Other:
GWUDI Ground Purchased

D. Contact Person*
Name: Mr. Ronald Doe, P.E.
Title: Water System Superintendent
Phone #: 123-555-0000
Fax#: 123-555-0001
E-mail: Rdoe@ci.elmcity.us

II. IDSE REQUIREMENTS*
A. Number of Sites
B. Schedule C.
Total: 4
Near Entry Point: 0 D Schedule 1 C
Avg Residence Time:
1 D Schedule 2
HighTTHM: 2 D Schedule 3 E
HighHAA5: 1 a Schedule 4 n
Standard Monitoring Frequency
H During peak historical month
1 monitoring period)
a Every 90 days (4 monitoring periods)
] Every 60 days (6 monitoring periods)
IDSE Guide for Systems Serving < 10,000
B-l
Jamian- 2006

-------
Standard Monitoring Plan Form for
Systems Serving < 10,000 page2of5
III. SELECTING STANDARD MONITORING SITES
A.
eac
B.
mo
Data Evaluated Put a V in each box corresponding to the data that you used to select
h type of standard monitoring site. Check all that apply.
Data Type
Type of Site
Near
Entry Pt.
Avg. Residence
Time
High
TTHM
High
HAAS
System Configuration
Pipe layout, locations of storage facilities
Locations of sources and consecutive
system entry points
Pressure zones
Information on population density
Locations of large customers





^




/


/

/


/

Water Quality and Operational Data
Disinfectant residual data
Stage 1 DBP data
Other DBP data
Microbiological monitoring data (e.g., HPC)
Tank level data, pump run times
Customer billing records






/





/
/


/

/
/


/
/
Summary of Data* Provide a summary of data you relied on to justify standard
nitoring site selection (attach additional sheets if needed)
We used residual data from Total Coliform sites collected from 2003 through 2005 and our current
system map to select sites. We evaluated chlorine residual data from June and July (range from 0.2 -
2.3 mg/L), and calculated our system average (0.9-1.1 mg/L). Sites with residuals close to this were
considered for average residence time sites. Residual data along with information on storage tanks,
booster stations, and operator notes were used to locate areas of high residence time for high TTHM
and HAAS sites. We do not have HPC data to identify potential biological activity, so we evaluated
residual data, coliform data, and customer complaint records. We plotted all of our candidate sites on
our map to ensure that they are geographically and hydraulically diverse.

1DSE Guide for Systems Serving < 10.000
B-2
January 2006

-------
Standard Monitoring Plan Form for
Systems Serving < 10,000 page3of5
IV. JUSTIFICATION OF STANDARD MONITORING SITES*


Standard
Monitoring
Site ID
(from
map)1
Standard
Monitoring
#1
Standard
Monitoring
#2
Standard
Monitoring
#3
Standard
Monitoring
#4
Site Type
a Near Entry Pt
B Avg. Res. Time
G High TTHM
0 High HAA5
G Near Entry Pt
rr Avg. Res. Time
B High TTHM
LI High HAA5
D Near Entry Pt
D Avg. Res. Time
B High TTHM
D High HAAS
n Near Entry Pt
D Avg. Res. Time
G High TTHM
IS High HAAS
Justification
See attached.
See attached.
See attached.
See attached.
' Verify that site IDs match IDs in Section IV and on your distribution system schematic (See Section VII
of this form).

V. PEAK HISTORICAL MONTH AND STANDARD MONITORING SCHEDULE
A. Peak Historical Month* July
B. If Multiple Sources, Source Used to Determine Peak Historical Month
(write "N/A" if only one source in your system):
N/A
C. Peak Historical Month Based On* (check all that apply)
EI High TTHM B Warmest water temperature
H High HAAS
If you used other information to select your peak historical month, explain here
(attach additional sheets if needed)


JDSE Guide for Systems Serving < 10.000
B-3
Jonuarv 2006

-------
Standard Monitoring Plan Form for
Systems Serving < 10,000
Page 4 of 5
V. PEAK HISTORICAL MONTH AND STANDARD MONITORING SCHEDULE (Continued)
D. Prc
>posed Standard Monitoring Schedule*
Standard Monitoring
Site ID
(from map) 1
SM#1
SM#2
SM#3
SM#4

Projected Sampling Date (date or week) 2
period 1
4/16/09
4/16/09
4/16/09
4/16/09
period 2
7/15/09
7/15/09
7/15/09
7/15/09
period 3
10/14/09
10/14/09
10/14/09
10/14/09
period 4
1/12/10
1/12/10
1/12/10
1/12/10

1 Verify that site IDs match IDs in Section IV and on your distribution system schematic (See Section
VII of this form).
? period = monitoring period. Complete for the number of periods from Section II. C. Can list exact
date or week (e.g., week of 7/9/07J
VI. PLANNED STAGE 1 DBPR COMPLIANCE MONITORING SCHEDULE


Stage 1 DBPR
Monitoring Site ID (from
map) 1
Staael #1(51-1)
*

Projected Sampling Date (date or week)2
period 1
4/15/09
period 2
7/14/09
period 3
10/13/09
period 4
1/11/10

' Verify that site IDs should IDs on your distribution system schematic (See Section VII of this form).
? period = monitoring period. Complete for the number of periods in which you must conduct Stage 1
DBPR monitoring during IDSE monitoring. Can list exact date or week (e.g., week of 7/9/07)
IDSE Guide for Systems Serving < 10,000
B-4
Januarv 2006

-------
  Standard Monitoring Plan Form for
  Systems Serving < 10,000	pages of 5
 VII. DISTRIBUTION SYSTEM SCHEMATIC*
 ATTACH a schematic of your distribution system.

   Distribution system schematics are not confidential and should not contain information
   that poses a security risk to your system.  EPA recommends that you use one of two
   options:

     Option 1:  Distribution system schematic with no landmarks or addresses
     indicated. Show locations of sources, entry points, storage facilities, standard
     monitoring locations, and Stage 1 compliance monitoring locations (required).  Also
     include pressure zone boundaries and locations of pump stations.  Provide map
     scale.

     Option 2:  City map without locations  of pipes indicated. Show locations of
     sources, entry points, storage facilities, standard monitoring locations, and Stage 1
     compliance monitoring locations (required).  Also include boundaries of the
     distribution system, pressure zone boundaries and locations of pump stations.
     Provide map scale.
 VIII.  ATTACHMENTS
        B Distribution System Schematic* (Section VII).

        E Additional sheets for the summary of data or site justifications (Sections III and IV).

        D Additional copies of Page 3 for justification of Standard Monitoring Sites (Section
          IV).

        D Additional sheets for explaining how you used data other than TTHM, HAAS, and
          temperature data to select your peak historical month (Section V).

        D Additional sheets for planned Stage 1 DBPR compliance monitoring schedule
          (Section VI).

     Total Number of Pages in Your Plan	7	
Note:  Fields with an asterisk (*) are required by the Stage 2 DBPR
IDSE Guide for Systems Serving < 10,000          B-5                             Januan' 2006

-------
                      Justification of Standard Monitoring Sites       Attachment #1

Standard Monitoring #1

Represents average residence time of water in the southern section of the system. Based on
chlorine monitoring results at TCR sample locations, we identified sample sites where chlorine
levels were close to the average chlorine residual for the entire distribution system. Monthly
average chlorine residuals at Standard Monitoring #1 range from 0.8 mg/L to 1.2 mg/L, and the
monthly average residual for the whole distribution system ranges from 0.9 mg/L to 1.1 mg/L.
There are no storage facilities between the treatment plant and this location.

Standard Monitoring #2

Represents high TTHM levels. This sampling location is believed to receive water from the
D'Evon Storage tank (a 4 MG tank located in the northeastern region of the distribution system)
during high demand periods and is at the entrance to a small subdivision cul-de-sac.  The
chlorine residuals at this location are generally very low, indicating this may be a hydraulic dead
end. The sample location is near the first house on the cul-de-sac (which has 12 homes total).

Standard Monitoring #3

Represents high TTHM levels in the southeastern part of the system.  This sample location is
located in a zone of the distribution system that has been recently developed. This connection
is located downstream from a chlorine booster station.  Chlorine residuals are normally in the
0.5 to 0.9 mg/L range.

Standard Monitoring #4

Represents high HAAS levels. Sample location is in an area approaching the perimeter of the
distribution system. Chlorine residual at this location ranges between 0.5 and 0.8 mg/L, and the
low number of TCR positives and  small amount of customer complaints led us to believe there
is little biological activity in the area. This location is in the southwestern section of the system.
IDSE Guide for Systems Serving < 10.000           B-6                                January 2006

-------
 Distribution System Map
                                    Attachment # 2
                                                                                North
                                                                                Drinking Walcr Source
                                                                                Walcr Treatment Plant
                                                                           H  Chlorine Booster Station




                                                                                Disinhut ion System Boundary




                                                                           (^  J  Monitoring Sites




                                                                                Elevated Storage Tank
IDSE Guide for Systems Serving < 10,000
B-7
Januaiy 2006

-------
                               This page intentionally left blank.
IDSE Guide for Systems Serving < 10,000            B-8                                   January 2006

-------
IDSE Report for Standard Monitoring for
Systems Serving < 10,000 page 1 of 6
I. GENERAL INFORMATION
A. PWS Information*
PWSID: US1111111
|B. Date Submitted* June 19, 2010

PWS Name: Elm City
PWS Address: 1234 Main Street
City: Elm City State: US Zip: 99999
Population Served 6,000

System Type:
ECWS
D NTNCWS


Source Water Type:
B Subpart H
3 Ground

C. PWS Operations
Residual Disinfectant Type: B Chlorine D C
Number of Disinfected Sources: 1 Surface

D. Contact Person*
Name: Mr

Ronald Doe, P.E.

Buying / Selling Relationships:
D Consecutive System
D Wholesale System
E Neither

hloramines D Other:
GWUDI Ground Purchased


Title: Water Superintendent
Phone #: (123)555-0000
Fax#: (123)555-0001
E-mail: Rdoe@ci.elmcity.us

II. STAGE 2 DBPR REQUIREMENTS*
A. Number of
Compliance Monitoring
Sites
Highest TTHM:
B. Schedule C
1 D Schedule 1
Highest HAA5: 1 D Schedule 2
Total: 2 D Schedule 3
B Schedule 4
Compliance Monitoring Frequency
D During peak historical month (1
monitoring period)
8 Every 90 days (4 monitoring periods)
IDSE Guide for Systems Serving < 10,000
B-9
January 2006

-------
IDSE Report for Standard Monitoring for
Systems Serving < 10,000
m.
A.
MONITORING RESULTS*
Did you deviate in any way from your approved standard El Yes
monitoring plan?
If YES, explain (attach additional pages if necessary):
This IDSE Monitoring Plan indicated samples should be taken on
January 12, 2010. A Snowstorm on that date caused hazardous
Page 2 of 6

DNo
road
conditions and prevented sampling. Samples were taken on January

B.
C.
18, 2010 once the roads were cleared.



Where were your TTHM and HAAS samples analyzed?
L I In-House
Is your in-house laboratory certified? D Yes
IS Certified Laboratory
Name of certified laboratory: Acme Laboratory Services

What method(s) was used to analyze your TTHM and HAAS
samples?
TTHM HAAS
D EPA 502.2 D EPA 552.1
D EPA 524.3 D EPA 552.2
B EPA 551.1 8 EPA 552.3
D SM 6251 B




DNo


IDSE Guide for Systems Serving < 10,000            B-10                                    Januaiy 2006

-------
IDSE Report for Standard Monitoring for
Systems Serving < 1 0,000 Page 3 of e
III. MONITORING RESULTS (Continued)*
D. SI
andard Monitoring and Stage 1 Compliance Monitoring Results - TTHM
Site ID1
Standard
Monitoring #1
Standard
Monitoring #2
Standard
Monitoring #3
Standard
Monitoring #4
Stage 1 #1
Data Type
Sample Date
Sample
Result
Sample Date
Sample
Result
Sample Date
Sample
Result
Sample Date
Sample
Result
Sample Date
Sample
Result

4/09
0.04
2
4/09
0.06
1
4/09
0.05
0
4/09
0.04
2
4/09
0.06
4
TTHM (mg/L)
7/09
0.060
7/09
0.067
7/09
0.061
7/09
0.057
7/09
0.068
10/09
0.054
10/09
0.069
10/09
0.056
10/09
0.046
10/09
0.083
1/10
0.039
1/10
0.059
1/10
0.045
1/10
0.035
1/10
0.074
LRAA

0.049

0.064

0.053

0.045

0.072
1 Verify that site IDs for IDSE standard monitoring sites match the site IDs in your
Standard Monitoring Plan.
Attach additional sheets as needed.

IDSE Guide for Systems Serving < 10,000
B-ll
Januan' 2006

-------
IDSE Report for Standard Monitoring for
Systems Serving < 1 0,000 page 4 of e
III. MONITORING RESULTS (Continued)*
E. St
andard Monitoring and Stage 1 Compliance Monitoring Results - HAAS
Site ID1
Standard
Monitoring #1
Standard
Monitoring #2
Standard
Monitoring #3
Standard
Monitoring #4
Stage 1 #1
Data Type
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
Sample Date
Sample Result
HAAS (mg/L)
4/09
0.031
4/09
0.039
4/09
0.043
4/09
0.055
4/09
0.021
7/09
0.043
7/09
0.045
7/09
0.035
7/09
0.074
7/09
0.025
10/09
0.033
10/09
0.041
10/09
0.043
10/09
0.054
10/09
0.026
1/10
0.025
1/10
0.028
1/10
0.031
1/10
0.049
1/10
0.028
LRAA

0.033

0.038

0.038

0.058

0.025
1 Verify that site IDs for standard monitoring sites match the site IDs in
your Standard Monitoring Plan.
Attach additional sheets as needed.
IDSE Guide jor Systems Serving < 10,000
B-12
Januarv 2006

-------
  IDSE Report for Standard Monitoring for
  Systems Serving < 10,000  	
                                                         Page 5 of 6
 IV. JUSTIFICATION OF STAGE 2 DBPR COMPLIANCE MONITORING SITES*
Stage 2
Compliance
Monitoring
Site ID
Stage 1 # 1
SM#4
Site Type
H Highest TTHM
D Highest HAAS
«
D Highest TTHM
H Highest HAAS
Justification
Stage 1 DBPR location #1 had the highest TTHM
LRAA among all the sites. Therefore, this location
was chosen as the first Stage 2 DBPR compliance
monitoring location.
Standard Monitoring #4 site had the highest HAAS
LRAA among all of the sites.
 V. PEAK HISTORICAL MONTH AND PROPOSED STAGE 2 COMPLIANCE MONITORING
 SCHEDULE
 A.

 B.
Peak Historical Month*   July
Is Your Peak Historical Month the Same as in Your Standard Monitoring
Plan?
       Yes
        DNo
     If no, explain how you selected your new peak historical month (attach
     additional sheets if needed):
 C.  Proposed Stage 2 DBPR Compliance Monitoring Schedule*
Stage 2
Compliance
Monitoring
Site ID
Stage 1 # 1
SM#4
Projected Sampling Date (date or week)1
period 1
10/9/13
10/9/13
period 2
1/9/14
1/9/14
period 3
4/9/14
4/9/14
period 4
7/8/14
7/8/14
     1 period = monitoring period. Complete for the number of monitoring periods
     from Section II. C.
IDSE Guide for Systems Serving < 10,000
                             B-13
January 2006

-------
 1DSE Report for Standard Monitoring for
 Systems Serving < 10,000                	        Pageeofe
 VI. DISTRIBUTION SYSTEM SCHEMATIC1
 ATTACH a schematic of your distribution system if it has changed since you submitted
 your Standard Monitoring Plan.
 VII. ATTACHMENTS
     n Additional sheets for explaining how and why you deviated from your standard
       monitoring plan (Section III).

     "3 Additional sheets for Standard Monitoring and Stage 1 DBPR monitoring results
       (Section III).

     LJ Additional sheets for explaining how you selected the peak historical month (Section
       V).

      1 Distribution system schematic* (Section VI). REQUIRED if it has changed from
       your approved IDSE standard monitoring plan.

     ; ] Compliance calculation procedures (for Stage 2 Compliance Monitoring Plan).


 Total Number of Pages in Your Report:	6	
Note:  Fields with an asterisk (*) are required by the Stage 2 DBPR
IDSE Guide for Systems Serving < 10,000         B-14                             January 2006

-------