^DS%\ Complying with the Stage 2
Disinfectant and Disinfection
Byproducts Rule: Small Entity
Compliance Guide
the Simple Tools for
(STEP) Guide Series
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United States Environmental Protection Agency
Office of Groundwaterand Drinking Water
(4607M)
www.epa.gov/safewater
EPA815-R-07-014
February 2007
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NOTICE
This guide was prepared pursuant to section 212 of the Small Business Regulatory
Enforcement Act of 1996 ("SBREFA"), Pub.L. 104-121. The statements in this document
are intended solely as a guide to aid you in complying with the Stage 2 Disinfectant and
Disinfection Byproduct Rule (71 FR 388, January 4, 2006). In any civil or administrative
action against a small business, small government, or small non-profit organization for a
violation of the Stage 2 Disinfectant and Disinfection Byproduct Rule, the content of this
guide may be considered as evidence of the reasonableness or appropriateness of
proposed fines, penalties, or damages. EPA may decide to revise this guide without
public notice to reflect changes to EPA's approach to implementing the Stage 2
Disinfectant and Disinfection Byproduct Rule or to clarify or update text. To determine if
EPA has revised this guide and/or to obtain copies, contact EPA's Small Business
Ombudsman Office at 1-800-368-5888 or 202-566-2822 (Washington DC metropolitan
calling area) or the Office of Ground Water and Drinking Water Safe Drinking Water
Hotline at 1-800-426-4791 (e-mail: hotline-sdwa@epa.gov).
The statutory provisions and EPA regulations presented in this document contain legally
binding requirements. This document is not a regulation itself, nor does it change or
substitute for those provisions and regulations. It does not impose legally binding
requirements on EPA, States or public water systems. While EPA has made every effort
to ensure the accuracy of the discussion in this guidance, the obligations of the
regulated community are determined by States, regulations or other legally binding
requirements. In the event of a conflict between the discussion in this document and any
statute or regulation, this would not be controlling.
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Primacy Agency
The primacy agency for almost all drinking water systems is the State drinking water or health agency. In
some cases, however, EPA or tribal governments are the primacy agency. For example, as of the publication
of this guide, the primacy agency for systems located in the Navajo Nation is the tribal office, and the primacy
agency for systems located on other Tribal lands, in Wyoming, or in the District of Columbia is the EPA
Regional office for that geographic area. For the remainder of this document we will refer to the primacy
agency as the "State," but this also refers to EPA and any tribal government for systems that have one
of them as a primacy agency.
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Contents
STEP #1 - Is this Guide for Me? 1
STEP#2-WhatWill I Learn? 2
STEP #3 - What is the Stage 2 DBPR? 4
General Requirements 4
Compliance Timeline 5
How Does this Rule Relate to Other Federal, State, and Local Requirements? 7
Where do DBFs come from? 7
Ensuring Safe Drinking Water 7
STEP #4 - What Does Compliance Monitoring Involve? 8
Routine Compliance Monitoring Requirements 9
Monitoring Plan 10
Monitoring Locations 11
Selecting your Stage 2 Monitoring Sites from TTHM and HAAS Data 11
Stage 2 Monitoring Site Selection Worksheet 11
Using the TTHM and HAAS Planning Worksheets for the Stage 2 DBPR 13
Explanation of Example TTHM and HAAS Worksheet 15
Selecting your Stage 2 Monitoring Sites without Previous Data 17
High TTHM Site 17
High HAAS Site 18
Monitoring Schedule 18
Monitoring Plan Template 19
Reduced Monitoring 21
Increased Monitoring 22
Compliance Determination and MCL Violations 23
Examples of Calculating Compliance 24
What if I use Chlorine Dioxide or Ozone? 24
STEP #5 - What Else Does the Stage 2 DBPR Require? 25
Laboratory Methods and Certification 25
Operational Evaluations 25
Operational Evaluation Levels Worksheet 26
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Reporting and Recordkeeping Requirements 28
Public Notice 29
Consumer Confidence Reports 29
Monitoring and Reporting Violations 30
Compliance Assistance 30
Planning 31
Testing 32
Operational Improvements 33
Upgrading or Installing New Treatment Technologies 34
Chloramination 34
Ultraviolet Light 35
Granular Activated Carbon Adsorption 35
Working with your Wholesale System (if you are a consecutive system) 36
Partnerships with Other Water Systems 36
Changing Source Water 37
Financial Assistance 38
Extensions for Systems that Need More Time to Comply 39
Exemptions 39
IV
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Additional copies of this guide are available from the Safe Drinking Water Hotline at (800)
426-4791. Please reference document number EPA 815-R-07-014. You can also download
the guide from EPA's Safe Drinking Water Web site at www.epa.gov/safewater/smallsys/ssinfo.htm
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ART: Average residence time
BAT: Best available technology
CWS: Community water system
DBF: Disinfection byproducts
DBPR: Disinfectants and Disinfection Byproducts Rule
DWSRF: Drinking Water State Revolving Fund
EPA: United States Environmental Protection Agency
FACA: Federal Advisory Committee Act
FR: Federal Register
GAC10: Granular activated carbon with ten minute
empty bed contact time and 180 day
reactivation frequency
GAC20: Granular activated carbon with twenty minute
empty bed contact time and 240 day
reactivation frequency
GWR: Groundwater Rule
GWUDI: Gound water under the direct influence of
surface water
HAAS: Haloacetic acids (five) (sum of
monochloroacetic acid, dichloroacetic acid,
trichloroacetic acid, monobromoacetic acid, and
dibromoacetic acid)
ICR: Information Collection Rule
IDSE: Initial distribution system evaluation
IESWTR: Interim Enhanced Surface Water Treatment
Rule
LRAA: Locational running annual average
LT1ESWTR: Long Term 1 Enhanced Surface Water
Treatment Rule
LT2ESWTR: Long Term 2 Enhanced Surface Water
Treatment Rule
MCL: Maximum contaminant level
MCLG: Maximum contaminant level goal
M-DBP: Microbial and Disinfectants/Disinfection
Byproducts
mg/L: Milligrams per liter
MRDL: Maximum residual disinfectant level
MRT: Maximum residence time
NOM: Natural organic matter
NTNCWS: Nontransient noncommunity water system
PWS: Public water system
SBREFA: Small Business Regulatory Enforcement
Fairness Act
SDWA: Safe Drinking Water Act, as amended in 1986
and 1996
SWTR: Surface Water Treatment Rule
TCR: Total Coliform Rule
TOC: Total organic carbon
TTHM: Total trihalomethanes
UV: Ultraviolet light
VSS: Very small system
VI
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,5,
1!
This guide is designed for owners and operators of small community water systems (CWSs) and non-transient non-community water
systems (NTNCWSs) serving fewer than 10,000 people that are required to comply with
the Stage 2 Disinfectants and Disinfection Byproducts Rule (Stage 2 DBPR). The Stage 2
DBPR applies to systems that meet all of the following four criteria:
Systems: All CWSs and NTNCWSs, including consecutive systems
Sources: All sources (surface water, ground water, ground water under the direct
influence, and purchased water)
Population Served: All sizes, and
Treatment: Systems that disinfect or deliver water that has been disinfected using
anything other than ultraviolet light (UV).
Systems that will typically find this guide useful include:
Small towns
Rural water districts
Tribal systems
Manufactured housing
Homeowners associations
Small private systems
Factories, schools, and
religious institutions that have
their own water supplies
Note: If you are a consecutive system, meaning that you receive some or all or your
water from another water system (see definition on page 3), you may also want to refer to EPA's Consecutive Systems Guidance
Manual for more information on operational and capital changes and strategies that will enable consecutive systems to comply with the
Stage 2 DBPR. See Appendix B for how to get copies of this or other guidance manuals and information about the Stage 2 DBPR.
Community water systems (CWSs) include all systems (regardless of ownership) that serve at least 25 year-round residents or 15
year-round service connections.
Non-transient non-community water systems (NTNCWSs) include all systems (regardless of ownership) that are not CWSs and that
regularly serve at least 25 of the same people for at least 6 months of the year.
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f "f"
,11 I
As a drinking water system's owner or operator, your most important job is protecting the health of your customers. This guide will help you
by providing information about the following:
• How the Stage 2 DBPR affects your system
• Why high levels of disinfection byproducts (DBFs) may affect the health of your
customers
• Your monitoring responsibilities under the Stage 2 DBPR, including worksheets to
help you track your progress
• What to report to your State (or EPA) and customers
• The Compliance Assurance Process
• How to determine if your system has high levels of DBPs
• Strategies to reduce high levels of DBPs in your drinking water
• Sources of funding for your Stage 2 DBPR compliance strategy
• How to prepare for the Stage 2 DBPR compliance dates
Appendix A contains a glossary of terms used both in the rule and in this guide. Appen-
dix B lists additional resources on the Stage 2 DBPR that you might find helpful and
detailed instructions on how to order them, including how to get a complete copy of the
rule. Appendix C lists contacts for States and Tribes. Appendix D identifies other STEP
guides that EPA has developed to assist small systems.
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Some Important Definitions for Understanding the Stage 2 DBPR
Consecutive systems include all systems that receive some or all of their finished water from another public water system on a regular basis.
Finished water is water that has been introduced into the distribution system of a public water system and is intended for distribution and consumption
without further treatment, except as necessary to maintain water quality in the distribution system (e.g., booster disinfection, addition of corrosion
control chemicals).
A wholesale system is a public water system that treats source water as necessary and then delivers finished water to another public water system.
Delivery may be through a direct connection or through the distribution system of another consecutive system.
The combined distribution system is defined as the interconnected distribution system consisting of the distribution systems of wholesale systems
and of the consecutive systems that receive finished water from those wholesale system(s).
Treatment
Plant
Wholesale System
Consecutive System
Consecutive System
System A
System B
System C
Combined Distribution
System
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EPA finalized the Stage 2 Disinfectants and Disinfection Byproduct Rule (DBPR) to reduce potential health risks from DBFs. The Long Term
2 Enhanced Surface Water Treatment Rule (LT2ESWTR) is being finalized and implemented at the same time as the Stage 2 DBPR to
ensure that drinking water is safe from both microbial pathogens and DBFs.
To comply with the Stage 2 Disinfectants and Disinfection Byproducts Rule (Stage 2
DBPR), published on January 4, 2006 (71 FR 388) systems must do the following:
• Conduct an Initial Distribution System Evaluation (IDSE) to find locations in
the distribution system that have high levels of TTHM and HAAS and that can be
used as compliance monitoring sites for the Stage 2 DBPR.
Note: This guide is the second of two small system guidance manuals for the
Stage 2 DBPR. For information on how small systems should conduct an
IDSE, see the Initial Distribution System Evaluation Guide for Systems Serving
< 10,000. This guide covers all remaining Stage 2 requirements, including
LRAAs, Stage 2 compliance monitoring, and operational evaluations.
• Use a locational running annual average (LRAA) calculation to determine
compliance with the Stage 2 DBPR maximum contaminant levels (MCLs) of:
- 0.080 mg/L for total trihalomethanes (TTHM), and
- 0.060 mg/L for five haloacetic acids (HAAS).
Note: The MCL values are the same as the Stage 1 MCLs; only the calculation method changes.
• Monitor for Stage 2 compliance at the required number of locations for each system's retail population
• Identify when TTHM or HAAS levels exceed the operational evaluation level and, when this happens, look at source water, opera-
tional practices, and treatment to find ways to reduce TTHM and HAAS concentrations in the distribution system.
Each of these general requirements are covered in more detail in the rest of this guidance manual.
The Stage 2 DBPR is an extension of the Stage 1 Disinfectants and Disinfection Byproducts Rule (Stage 1 DBPR). Systems must also
continue to comply with the other requirements of the Stage 1 DBPR in addition to meeting the requirements of the Stage 2 DBPR. This
includes compliance with the MCLs for bromate (for systems using ozone) and chlorite (for systems using chlorine dioxide), the MRDLs for
chlorine or chloramine (depending on the residual disinfectant used), as well as TOC removal requirements.
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Your compliance schedule for the Stage 2 DBPR are based on whether your system is part of a combined distribution system:
• If your system js part of a combined distribution system, you must comply with the
revised MCLs by the same date as required for the largest system in your com- Definition of population served:
bined distribution system. The total number of people served directly by a
Example: if your system serves 8,000 people, but you purchase water from a water system. Systems typically work with their
system that serves 250,000 people, you must comply by the dates shown for State to determine population served for corn-
Schedule 1 in the compliance timeline on the next page. pliance purposes.
• If your system is not part of a combined distribution system, compliance dates are
based on the population served by your system.
If you are using this guidance manual, you likely serve fewer than 10,000 people and you must comply by the dates shown for Sched-
ule 4 in the compliance timeline on the next page.
Your State (or EPA) should have sent you a letter telling you what schedule you are on. If you did not receive this letter or you
have questions about your schedule, contact your State (contact information is listed in Appendix C). Note: You are on the same
schedule for Stage 2 DBPR compliance as you were on for the IDSE.
The timeline on the next page shows important dates for the Stage 2 DBPR as well as periods for Cryptosporidium and E. coli required
under the LT2ESWTR.
Note: The figure shows the 2-year period after systems must begin compliance as a "possible extension." States may give you up to an
additional 2 years to comply if you need time to install capital improvements.
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Schedule 1
Systems serving
> 100,000 people1
Schedule 2
Systems serving
50,000 to 99,999 people1
Schedule 3
Systems serving
10,000 to 49,999 people1
Schedule 4
Systems serving
< 10,000 people1
2006
2007
2008
| LT2 Crypto monitoring
!
IDSE Plan D
October 1 , 2(
ID!
Ap
2006
| IDSE mon.
je
)06
IDSE
Janua
2009
Rep
ry1
| LT2 Crypto monitoring
t
3E Plan Due
ril 1,2007
I
IDSE Plar
October '
ID!
Ap
2007
IDSE
mon.
LT2
i Due
,2007
t
3E Plan D
ril 1,2008
ID!
Jul
Crypto
IDSE
ort Du
,2009
\
SERep
y 1,20
2010
Treatment
e
2011
2012 | 2013
J
f2014
Installation | Possible Extension
•
Be
Ap
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gin Compliance
•111,2012 I
Treatment Installation 1 Possible
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ort
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monitoring
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Begin Compl
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ance
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Treatment Installation
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iuary 1, 2010
3
LT2 Crypto monitoring2 j
mon. t
2009
I
Ln
j
~l
zxtension I
J
2015
Possible Extension '
t I
Begin Compliance
October 1,2013
Treatment Installation2
IDSE Report
July 1,2010
2010
Due
2011
2012
Begin
Octob
n
Possible Extension I
-T- J
FT
Co
er1
2013
npliance2
,2013
2014
2015
1 Includes systems that are part of a combined distribution system in which the largest system serves this population.
'' Subpart H systems serving fewer than 10,000 that must conduct Crypto monitoring have an additional 12 months to comply with
Stage 2 DBPR MCLs.
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How Does this Rule Relate to Other Federal, State, and Local Requirements?
As noted earlier, the Stage 2 DBPR is an extension of the Stage 1 Disinfectants and Disinfection Byproducts Rule (Stage 1 DBPR). The
Stage 2 DBPR and the Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) were published together to address the bal-
ance between protection from microbial pathogens and the potential health effects from disinfectants and their byproducts. You are still
required to continue to meet all existing federal requirements. You may call the Safe Drinking Water Hotline at (800) 426-4791 (e-mail:
hotline-sdwa@epa.gov) for more information on other drinking water rules.
This guide explains your federal requirements for the Stage 2 DBPR. There may be additional State or local drinking water regulations for
DBPs that apply to your system and that are different from, or more stringent than, the federal requirements explained here. For more
information on your State's requirements, please contact your State drinking water office. State contacts are listed in Appendix C or are
available through the Safe Drinking Water Hotline at (800)426-4791 (e-mail: hotline-sdwa@epa.gov).
Where do DBPs come from?
Chlorine and other chemical disinfectants have been widely used by public water systems (along with filtration) to protect the public from
microbial pathogens in drinking water. DBPs are formed when certain disinfectants react with DBP precursors (organic and inorganic
materials) in source waters. In most cases, natural organic matter (NOM) is an important factor that affects the levels of DBPs that form
(NOM is usually measured as TOC). The levels of DBPs in drinking water can vary significantly from one point in a distribution system to
another, as many continue to form in the distribution system. DBP levels are generally higher in surface water systems because surface
water usually contains higher DBP precursor levels and requires stronger disinfection.
Please see Appendix B for a list of references that provide more information on DBP formation.
Ensuring Safe Drinking Water
All drinking water systems want to provide water that is safe. One aspect of providing safe drinking water is limiting the levels of DBPs in it.
Long-term exposure to DBPs has been linked to bladder cancer, and possibly colon and rectal cancers. More recent studies have shown
that shorter-term exposure to high levels of DBPs may be associated with adverse reproductive and developmental health effects.
Limiting the levels of DBPs in your drinking water may require you to make some adjustments to your current operations, such as:
• Making operational improvements at the plant or in the distribution system (see page 34 for more information)
• Modifying current treatment operations to remove more DBP precursors or form lower levels of DBPs (Page 34 has more information)
• Upgrading or installing a new treatment technology (see page 35 for more information)
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r. 1
:» 1
J -,"•
Monitoring requirements for TTHM and HAAS are based on your source water type and the population your system serves. Note that this is
different than the Stage 1 DBPR monitoring requirements that were based on the number of treatment plants in your system.
With population-based monitoring, there are five categories of small systems under the Stage 2 DBPR:
• Subpart H systems that serve fewer than 500 people.
• Subpart H systems that serve 500 to 3,300 people.
• Subpart H systems that serve 3,301 to 9,999 people.
• Ground water systems that serve fewer than 500 people.
• Ground water systems that serve 500 to 9,999 people.
If you do not know what type of system you are, you should contact
your State to confirm this information.
Subpart H systems are
systems that use surface
water or ground water under
the direct influence of surface
water (GWUDI) as their
source water. If any of your
water is from a surface
water or GWUDI source,
you are a Subpart H sys-
tem. This includes systems
that purchase surface water
or GWUDI as well as sys-
tems that have mixed sur-
face water and ground water
sources.
*•'
~* • ri| --,3" tlfcnt1 . •'•
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Routine
The locations and frequencies
required for routine compliance
monitoring requirements for your
system are listed in the table
below. For all systems, at least
one sample must be taken
during the month of highest DBF
concentration or warmest water
temperature.
• Subpart H systems serv-
ing 3,301-9,999 and
Ground water systems
serving 500-999:
You are required to take dual
samples (one for TTHM and
one for HAAS) at the loca-
tions and frequencies listed
in the table on this page.
Source Water Type
Subpart H
Ground Water
Population Size
Category
<500
500 - 3,300
3,301 - 9,999
<500
500 - 9,999
Monitoring
Frequency1
yearly
every 90 days
every 90 days
yearly
yearly
Distribution System Monitoring Location
Total per
monitoring
period
22
22
2
22
2
Highest TTHM
Locations
1
1
1
1
1
Highest HAAS
Locations
1
1
1
1
1
1AII systems must take at least one dual sample set during the month of highest DBP concentrations or warmest water temperature.
2System is required to take individual TTHM and HAAS samples (instead of 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.
Subpart H systems serving up to 3,300 people and Ground water systems serving fewer than 500 people:
You are required to take individual samples (instead of a dual sample set) at the locations and frequencies shown in the table below, so
you will sample for TTHM at the location with representative high TTHM concentrations and sample for HAAS at the location with repre-
sentative high HAAS concentrations. However, if the highest TTHM and HAAS concentrations occur at the same location in your distribu-
tion system, you can collect a dual sample set at one location per monitoring period (see table footnote).
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If you conducted standard monitoring or a system specific study for the IDSE, the locations and schedule for your Stage 2 compliance
monitoring were submitted as part of your IDSE report. You should follow your approved Stage 2 monitoring plan. You can skip this next
section and go to page 21 to continue learning about Stage 2 compliance monitoring.
If you received a 40/30 certification for the IDSE, or if you were
not required to conduct an IDSE, you must develop a monitoring
plan that includes:
• When and where you intend to monitor TTHM and HAAS for
Stage 2 DBPR compliance.
• What compliance calculation procedures you intend to use.
• Monitoring plan for any other systems in the combined distribu-
tion system if your State has reduced monitoring requirements
under §141.16(m). You should contact your State if you are
uncertain of these requirements.
REMINDER
The following types of systems should have conducted an IDSE or
received a 40/30 certification or very small system waiver:
• All CWS that deliver water disinfected with anything other than UV.
• All NTNCWS that serve at least 10,000 people and deliverwater
disinfected with anything other than UV.
For more information on IDSE requirements for small systems, see the
Initial Distribution System Evaluation Guide for Systems Serving <
10,000.
If you received a very small system (VSS) waiver for the IDSE,
you should continue to monitor at the same location for Stage 2 DBPR compliance monitoring unless you have data showing that your
highest TTHM and HAAS concentrations occur at a different location.
If you are a Subpart H system and you serve more than 3,300 people, you must submit a copy of your monitoring plan to your State for
review before you take your first Stage 2 compliance sample. All other systems must keep the monitoring plan on file for State and public
review.
If you have not developed a Stage 2 DBPR monitoring plan, continue reading the next section to learn how to choose your monitoring
locations and schedule.
10
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Monitoring Locations
You can determine the appropriate Stage 2 monitoring locations by using TTHM and HAAS data. If you haven't collected TTHM and HAAS
data before, you will need to use other knowledge about your system to select appropriate sites.
Selecting your Stage 2 Monitoring Sites from TTHM and HAAS Data
If you monitored at several locations under the Stage 1 DBPR, you can use your existing TTHM and HAAS data to determine where you
should monitor. Start by calculating the LRAA for TTHM and HAAS at each Stage 1 DBPR monitoring site.
If you were not required to monitor under Stage 1 or monitored at fewer locations than you will need for Stage 2 compliance monitoring, turn
to page 17 to learn how to select your Stage 2 monitoring sites.
Stage 2 Monitoring Site Selection Worksheet
The following worksheet is provided to help you organize your existing data. Several copies of the worksheet are provided. The first copy is
followed by instructions on how to complete it. The second copy is an example. The third is a blank worksheet that you can use or photo-
copy.
If you prefer, an electronic form is also available that allows you to enter your data and calculates your LRAAs for you. You can find this form
on EPA's Web site at http://www.epa.gov/safewater/stage2/index.html. If you choose not to use this form, you could consider using a
spreadsheet (such as Microsoft Excel or Lotus 123) to store your data and calculate your LRAA.
11
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TTHM Worksheet - Stage
Sampling
1
Site
Site Type
7
Quarter 1
Quarter 2
Quarter 3
3
Quarter 4
2DBPR
LRAA
4
Is this the highest TTHM site?
5
Site Selection
6
HAAS Worksheet - Stage
Sampling
1
Site
Site Type
7
Quarter 1
Quarter 2
Quarter 3
3
Quarter 4
2DBPR
LRAA
4
Is this the highest HAAS site?
5
Site Selection
6
12
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the and for the 2
This section provides step-by-step instructions on how to use the TTHM and HAAS planning worksheet. Each step corresponds to a num-
bered section of the sample worksheet. Note that you are not required to use this worksheet, it is simply provided to help you organize your
monitoring results.
Enter location of the sampling sites, including:
Step #1 • All Stage 1 DBPR sampling sites Step #4
• Any additional TTHM or HAAS locations
sampled
Enter the type of sampling site.
Step #2 For Stage 1 DBPR (all plants):
• Maximum Residence Time, or Step #5
• Additional Monitoring Site
Enter the four most recent monitoring results
Step #3 for each location.
• If you have older data, you may also want to Step #6
look at years with high TTHM and HAAS levels
(which often occur during warm weather or
periods with high TOC) on another copy of
this worksheet.
• Do not look at data collected earlier than the
last treatment/distribution system change.
• If you monitor yearly, you will be looking at just
one location.
Calculate the LRAA for each sampling site.
The LRAA calculation is the running annual aver-
age at each sampling location.
LRAA = Q1+Q2+Q3+Q4
4
Note which location has the highest LRAA.
• Enter "Yes" in this column if that site has the
highest LRAA for TTHM or HAAS, otherwise
enter "No."
Select Stage 2 Compliance Monitoring Sites.
• Select the location with the highest TTHM
LRAA (Yes in Step 5) as your High TTHM site.
• Select the location with the highest HAAS LRAA
(Yes in Step 5) as your High HAAS site.
• If your highest TTHM and HAAS LRAAs occur
at the same site, choose your second highest
HAAS LRAA as your High HAAS site.
• Subpart H systems < 3,300 and ground water
systems < 500 can take a dual sample set at
one location if highest TTHM and HAAS LRAAs
occur at the same site (otherwise take one
sample at two separate locations for High
TTHM and High HAAS).
13
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TTHM Worksheet - Stage 2 DBPR
Sampling Site
Stage 1 #1
Stage 1 #2
Extra Monitoring site
Site Type
MRT
MRT
ART
Quarter 1
0.048
0.068
0.036
Quarter 2
0.054
0.081
0.068
Quarter 3
0.087
0.090
0.065
Quarter 4
0.063
0.074
0.055
LRAA
0.063
0.078
0.056
Is this the highest TTHM site?
No
Yes
No
Site Selection
High TTHM Site
HAAS Worksheet - Stage 2 DBPR
Sampling Site
Stage 1 #1
Stage 1 #2
Extra Monitoring site
Site Type
MRT
MRT
ART
Quarter 1
0.024
0.012
0.035
Quarter 2
0.024
0.035
0.046
Quarter 3
0.035
0.032
0.061
Quarter 4
0.045
0.034
0.054
LRAA
0.032
0.028
0.049
Is this the highest HAAS site?
No
No
Yes
Site Selection
High HAA5 Site
14
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of
This system is a NTNCWS that treats surface water at two plants and serves 5,000 people. Since the system is a NTNCWS that serves
fewer than 10,000 people, it did not conduct an IDSE. Under Stage 1 DBPR, this system is required to take two samples per quarter at
maximum residence time locations (one sample for each plant during each quarter).
On the example worksheet, the system recorded all the monitoring results from the last year. The system also included monitoring results
from a third location that they sampled last year as part of a research project.
The system then calculated the LRAAforTTHM and HAAS at each different monitoring site. For example:
Stage 1 #1 TTHM: LRAA = Q1+Q2+Q3+Q4
4
LRAA = (0.048+0.054+0.087+0.063)
4
LRAA = 0.252
4
LRAA = 0.063 mg/L
The system then compared the LRAA results for each site and noted which site had the highest LRAA.
The LRAA at Stage 1 site #2 was highest for TTHM, so the system will use this location as the Stage 2 High TTHM compliance monitoring
site. The highest HAA5 LRAA was at the extra monitoring site, so the system will use this location as the Stage 2 High HAA5 compliance
monitoring site.
15
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TTHM Worksheet - Stage 2 DBPR
Sampling Site
Site Type
Quarter 1
Quarter 2
Quarter 3
Quarter 4
LRAA
Is this the highest TTHM site?
Site Selection
HAAS Worksheet - Stage 2 DBPR
Sampling Site
Site Type
Quarter 1
Quarter 2
Quarter 3
Quarter 4
LRAA
Is this the highest HAAS site?
Site Selection
16
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2
If you do not have TTHM or HAAS data or if you need to select more monitoring sites for Stage 2 DBPR than you have data for, you will have
to use other knowledge about your system to identify one high TTHM and one high HAAS location in your distribution system that are appro-
priate monitoring sites. Each site type has certain characteristics that will help you locate appropriate monitoring sites. You may also want to
consider the following when selecting your Stage 2 monitoring sites:
• Geographic distribution of monitoring sites.
• Sites that are already used for compliance with other rules (e.g., Total Coliform Rule [TCR]).
• Site accessability.
Site
You should choose your high TTHM site to represent areas in the
distribution system where you expect to find higher levels of TTHM Characteristics of High TTHM Sites
throughout the year as compared to other sites. Higher temperatures
and increased residence time typically lead to higher TTHM concen- Hi9n TTHM sites are often located:
trations Low disinfectant residual usually indicates longer residence * Near tne ends °f tne distribution system, at or before the last group of
time sites. customers.
• In mixing zones where water from different sources combine within the
distribution system.
• Downstream of storage facilities -especially those with a common
inlet and outlet prior to the last fire hydrant.
Sample sites should not be located:
• At a dead-end where there are no customers.
• Immediately prior to booster disinfection.
17
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Your high HAAS site should be chosen to represent areas in the
distribution system where you expect to find higher levels of HAAS
throughout the year as compared to other sites. Higher temperatures
and increased residence time can lead to higher HAAS concentra-
tions. However, HAAS can biodegrade when disinfectant residual
levels are low or non-existent. Therefore, a high HAAS site will not
necessarily be the site with the longest residence time.
If you conducted standard monitoring or a system specific
study for the IDSE, the schedule for your Stage 2 compliance
monitoring was submitted as part of your IDSE report. You should
follow your approved Stage 2 monitoring plan. You can skip this next
section and go to page 21 to continue learning about Stage 2 compli-
ance monitoring.
Characteristics of High HAAS Sites
High HAAS sites are often located:
• In areas with low but existing disinfectant residual(generally, disinfec-
tant residual levels should be consistently above 0.2 mg/L for chlorine
or 0.5 mg/L for chloramine).
• Near the ends of the distribution system, at or before the last group of
customers.
• In mixing zones where water from different sources combines within
the distribution system..
• Downstream of storage facilities.
• Prior to the last fire hydrant.
Sample sites should not be located:
• At a dead-end where there are no customers.
• Immediately prior to booster disinfection.
• Where no disinfectant residual exists.
• Areas with biofilm problems.
If you received a 40/30 certification or a very small system
(VSS) waiver for the IDSE, or if you were not required to conduct an IDSE, you must develop a monitoring schedule for Stage 2 DBPR
compliance. The Stage 2 DBPR requires that systems conduct monitoring during the peak historical month forTTHM levels or HAAS levels
or the month of warmest water temperature. This is referred to as the "Controlling Month." It is meant to represent the "worst case" condi-
tions when DBFs are expected to be at the highest levels during the year.
18
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Since most small systems do not have TTHM or HAAS data more than quarterly, it is recommended that you use water temperature to
determine your controlling month. Although there are no regulations that require you to measure water temperature in your distribution
system or sources, many systems collect this information for process control. Other systems may have temperature data at different points
in the treatment plant. If your system measures the temperature of water leaving the treatment plant, consider averaging these data for each
summer month to identify the month of warmest water temperature. No matter which data you use, calculate the average for each summer
month to identify the month of warmest temperature. This is your controlling month.
All systems are required to monitor during their controlling month, regardless of system size or monitoring frequency. If you monitor yearly,
you will sample yearly during this month. If you monitor quarterly, you will sample during this month and every 90 days before and/or after the
peak historical month to meet your monitoring requirements.
Note: You do not have to sample at exactly the frequency required for your system. Sampling within the same week during each required
month is sufficient. For example, if you are required to sample every 90 days, you could sample during the second week of every third
month. If you are required to sample yearly, you could sample each year during the first week of your controlling month.
3,' Ml/ 11",? f'^IJf 5j/fi>
The following template is provided to help you organize your Stage 2 monitoring plan.
19
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Stage 2 DBPR Monitoring Plan
Stage 2 Compliance
Monitoring Site ID
Site Type
Justification
Projected Sampling Date (month/day/year) *
Period 1 Period 2 Period 3 Period 4
__ Highest TTHM
__ Highest HAAS
__ Stage 1 DBPR
__ Other
Highest TTHM
Highest HAAS
Stage 1 DBPR
Other
* Period = monitoring period. Complete for the number of monitoring periods required for your system.
Compliance Calculation Procedures
Monitor yearly, compliance calculated as sample result < MCLfor each location
Monitor quarterly, compliance calculated as LRAA = (Q1+Q2+Q3+Q4)/4 < MCLfor each location
Monitor more frequently than quarterly. Compliance calculated as follows:
Combined Distrubtion System Information
This PWS is part of a combined distrubution system
If Checked: Monitoring Requirements have been reduced by State and monitoring plans for other
systems are attached.
20
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Your system can qualify for reduced monitoring if you meet all three of the following criteria:
• The LRAA is < 0.040 mg/L for TTHM at all monitoring locations,
• The LRAA is < 0.030 mg/L for HAAS at all monitoring locations, and
• The source water annual average TOC level (before any treatment) is < 4.0 mg/L at each treatment plant treating surface water or
ground water under the direct influence of surface water.
Reduced monitoring requirements:
Source Water Type
Subpart H
Ground Water
Population Size
Category
<500
500-3,300
3,301 -9,999
<500
500 - 9,999
Reduced
Monitoring
Frequency
-
yearly
yearly
every third year
yearly
Distribution System Monitoring Location per Monitoring Period
Monitoring may not be reduced.
One TTHM and One HAA5 sample: one at the location and during the quarter with the highest TTHM
single measurement, one at the location and during the quarter with the highest HAA5 measurement;
one dual sample set per year if the highest TTHM and HAA5 measurements occurred at the same
location and quarter.
Two dual sample sets: one at the location and during the quarter with the highest TTHM single
measurement, one at the location and during the quarter with the highest HAA5 single measurement.
One TTHM and One HAA5 sample: one at the location and during the quarter with the highest TTHM
single measurement, one at the location and during the quarter with the highest HAA5 single
measurement; one dual sample set if the highest TTHM and HAA5 measurements occurred at the
same location and quarter.
One TTHM and one HAA5 sample: one at the location and during the quarter with the highest TTHM
single measurement, one at the location and during the quarter with the highest HAA5 single
measurement; one dual sample set per year if the highest TTHM and HAA5 measurements occurred
at the same location and quarter.
You may remain on reduced monitoring as long as samples remain below the following levels:
• Each TTHM sample is less than or equal to 0.060 mg/L, and
• Each HAAS sample is less than or equal to 0.045 mg/L, and
• The source water annual average TOC level (before any treatment) is <4.0 mg/L at each treatment plant treating surface water or ground
water under the direct influence of surface water.
21
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If you monitor yearly (or less frequently if on reduced monitoring), you must begin increased monitoring and sample every 90 days if:
• Any TTHM sample > 0.080 mg/L, or
• Any HAAS sample is > 0.060 mg/L.
Note that this is not an immediate violation. However, your system is in violation of the Stage 2 MCLs if the TTHM or HAAS LRAA exceeds
the MCL after four quarters of sampling.
You may return to routine monitoring from increased monitoring when all of the following criteria are met:
• You have conducted increased monitoring for at least four quarters, and
• LRAA for every monitoring location is < 0.060 mg/L for TTHM, and
LRAA for every monitoring location is < 0.045 for HAAS.
22
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Compliance with the TTHM and HAAS MCLs for Stage 2 DBPR is based on your monitoring results at each monitoring location.
If you monitor once per quarter:
• Compliance is based on the LRAA of monitoring results, calculated quarterly (see example on the next page).
• You must make compliance calculations beginning with the end of the fourth quarter of monitoring and continue calculations after each
quarter.
• If you fail to complete four consecutive quarters of monitoring, you must calculate compliance with the MCL based on the average of the
available data from the most recent four quarters.
• If you take more than one sample per quarter at a monitoring location, you must average all samples taken in the quarter at that location
to determine a quarterly average to be used in the LRAA calculation.
• If the LRAA at any location exceeds the MCL, you are in violation.
• Failure to monitor will be treated as a monitoring violation for the entire period covered by a locational running annual average compliance
calculation for the Stage 2 MCLs.
If you monitor once per year:
• Compliance is based on the value of the yearly samples at each location.
• You must make compliance calculations beginning with the first compliance sample taken after the compliance date.
• If any sample exceeds the MCL, you are not immediately in violation. You must begin increase monitoring immediately (monitor quarterly
at each location).
• If any sample exceeds the MCL and you are on reduced monitoring, you must begin increased monitoring immediately (monitor quarterly
at each location).
• Failure to monitor will be treated as a monitoring violation for the entire period covered by a locational running annual average compliance
calculation for the Stage 2 MCLs.
NOTE: Some States require you to submit your analytical results and the State will calculate compliance for you.
23
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Example Compliance Calculation for
Date
8/15/2013
11/14/2013
2/15/2014
5/12/2014
8/16/2014
11/12/2014
2/15/2015
TTHM
result
mg/L
0.096
0.072
0.060
0.088
0.120
0.060
0.048
LRAA for TTHM
(0.096+0+0+0)/4 = 0.024 mg/L
(0.096+0.072+0+0)/4 = 0.042 mg/L
(0.096+0.072+0.060+0)/4 = 0.057 mg/L
(0.096+0.072+0.060+0.088)/4 = 0.079 mg/L
(0.072+0.060+0.088+0.120)74 = 0.085 mg/L
(0.060+0.088+0.120+0.060)/4 = 0.082 mg/L
(0.088+0.120+0.060+0.048)/4 = 0.079 mg/L
TTHM
MCL
Violation?
No
No
No
No
Yes
Yes
No
Systems Monitoring Quarterly
LRAA for HAAS
HAAS
Result
mg/L
0.044 (0.044+0+0+0)74 = 0.011 mg/L
0.020 (0.044+0.020+0+0)/4 = 0.016 mg/L
0.024 (0.044+0.020+0.024+0)/4 = 0.022 mg/L
0.030 (0.044+0.020+0.024+0.030)/4 = 0.030 mg/L
0.050 (0.020+0.024+0.030+0.050)/4 = 0.031 mg/L
0.024 (0.024+0.030+0.050+0.024)/4 = 0.032 mg/L
0.012 (0.030+0.050+0.0240.012)/4 = 0.029mg/L
HAAS
MCL
Violation?
No
No
No
No
No
No
No
If I or
If you use chlorine dioxide as your disinfectant, your requirements under the Stage 1
DBPR have not changed.
If you use ozone, you will now qualify for reduced bromate monitoring based on fin-
ished water bromate levels instead of source water bromide levels. Systems with a
bromate running annual average less than or equal to 0.0025 mg/L (based on monthly
monitoring) qualify for reduced bromate monitoring. The effective date for this change
is March 31, 2009. In order to meet this deadline, you will need to start monitoring for
bromate using the new method by March 2008. All other requirements remain the same
as under the Stage 1 DBPR.
For more information, see the Small System Requirements for the Stage 1 DBPR:
Small Entity Compliance Guide.
Bromide (Br) occurs naturally in some source
waters. Higher levels of bromide may be cause
by brine or salt water intrusion. Bromide is a
precursor to bromate (along with other bromi-
nated DBFs).
Bromate (BrO3) is a disinfection byproduct
that is present in some finished water and
forms when ozone reacts with bromide during
treatment.
24
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STEP #5 - What Else Does the Stage 2 DBPR Require?
Laboratory Methods and Certification
Approved analytical methods must be used to for all monitoring requirements, including TTHM and HAAS. There are several new approved
methods available since the Stage 1 DBPR. Consistent with current regulations, only certified laboratories can analyze samples for compli-
ance with the MCLs. For more information on approved methods or to find a certified lab, call the Safe Drinking Water Hotline at (800) 426-
4791 (e-mail: hotline-sdwa@epa.gov).
Operational Evaluations
A system that is in full compliance with the Stage 2 DBPR LRAA MCL may still have
individual DBP measurements above 0.080 mg/L for TTHM and 0.060 mg/L for HAAS
since compliance is based on a four-quarter average. Because of concerns that high
levels of DBPs can occur even when the system is in compliance, there is an
additional requirement in the Stage 2 DBPR for operational evaluations.
If your operational evaluations levels (according to the equation to the right) are higher
than the MCL at any location in the distribution system, you must conduct an opera-
tional evaluation. Your operational evaluation must include:
• An examination of system treatment and distribution operational practices, includ-
ing:
— Storage tank operations
— Excess storage capacity
- Distribution system flushing
- Changes in sources or source water quality
- Treatment changes
- Any problems that may contribute to TTHM and HAAS formation
• What steps could be considered to minimize future exceedances
Operational evaluation levels (calculated at each
monitoring location):
IF Q1jLQ2jt2a3 > 0.080 mg/L for TTHM
4 or 0.060 mg/L for HAAS
where
Q3 = current quarter measurement
Q2 = previous quarter measurement
Q1 =quarter before previous quarter measurement
then the system must conduct an operational
evaluation
25
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You must submit your operational evaluation report to the State for review within 90 days after being notified of the high TTHM or HAAS
analytical result that causes the operational evaluation level to exceed the MCL.
Note: If you know the cause of the operational evaluation level, you can ask your State to limit the scope of your evaluation. Requesting
approval to limit the scope of the operational evaluation does not extend the schedule for submitting the operational evaluation report, which
is still due 90 days after notification of the high analytical result.
For more detailed information on operational evaluations, refer to the Operational Evaluations Guidance Manual.
The following worksheet will help you organize your existing TTHM and HAAS results to determine your operational evaluation levels. If you
prefer, an electronic form is also available that allows you to enter your data and calculates your operational evaluation levels for you. You
can find this form on EPA's Web site at http://www.epa.gov/safewater/stage2/index.html. If you choose not to use this form, you could
consider using a spreadsheet to store your data and calculate your operational evaluation levels.
26
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Operational Evaluation Levels Worksheet
TTHM Data
Stage 2 DBPR Location
TTHM Example #1
TTHM Example #2
Results from 2
Quarters Ago
A
0.065 mg/L
0.068 mg/L
Results from
Last Quarter
B
0.074 mg/L
0.075 mg/L
Results from
Current Quarter
C
0.087 mg/L
0.093 mg/L
Operational
Evaluation Level
D = (A+B+C+C)/4
0.078 mg/L
0.082 mg/L
Need to conduct evaluation?
(Yes if D > 0.080 mg/L)
No
Yes
HAAS Data
Stage 2 DBPR Location
HAAS Example #1
HAAS Example #2
Results from 2
Quarters Ago
A
0.050 mg/L
0.033 mg/L
Results from
Last Quarter
B
0.062 mg/L
0.041 mg/L
Results from
Current Quarter
C
0.070 mg/L
0.050 mg/L
Operational
Evaluation Level
D = (A+B+C+C)/4
0.063 mg/L
0.044 mg/L
Need to conduct evaluation?
(Yes if D > 0.080 mg/L)
Yes
No
27
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The State needs to know if the water in your system poses any health risks so it can help you protect your customers. You must report the
following information for each monitoring location to the State within 10 days of the end of any quarter in which monitoring is required:
• Number of samples taken during the last quarter.
• Date and result of each sample was taken during the last quarter.
• LRAAfor each monitoring location (unless your State calculates this for you).
• Whether the MCL was violated at any monitoring location.
• Any operational evaluation levels that were exceeded during the quarter and, if so, the location and date, and the calculated TTHM and
HAAS levels.
You must also keep a copy of your Stage 2 monitoring plan and all monitoring results for 10 years.
In addition, you must continue to report the information required under Stage 1. For more information on Stage 1 reporting requirements, see
the Small System Requirements for the Stage 1 DBPR: Small Entity Compliance Guide. These requirements include monitoring results,
arithmetic averages, and violations for:
• TOC monitoring (required if you are a Subpart H system that uses conventional treatment, optional if you want to qualify for reduced
TTHM and HAAS monitoring).
• Disinfectant residual (chlorine, chloramine, or chlorine dioxide) monitoring (required for all systems).
• Chlorite monitoring (required if you use chlorine dioxide).
• Bromate monitoring (required if you use ozone).
28
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Keeping your customers informed of their water quality is part of your
responsibility as a water system. Informed customers are more
likely to understand the need for a new treatment system, infrastruc-
ture changes, and rate increases if they become necessary.
In both cases where public notice is required, you must also send a
copy to your State.
If you are a CWS, you must include the following information in
your annual consumer confidence report:
• Highest overall LRAAfor both TTHM and HAAS.
• LRAA for all locations where the MCL is exceeded.
• Range of individual sample results for all monitoring locations.
If you:
Fail to monitor or report
results
Exceed the MCL for
either TTHM or HAAS as
an LRAA at any location
in the distribution system
You must notify
your customers
within:
1 year
30 days
Additional Notes:
You may be able to incorporate
this information into your CCR
instead of having a separate
notification.
29
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^tfa!
r M * I
is: tne CompHance
The process for calculating compliance and determining when MCL violations occur is explained on page 23.
You have committed a monitoring and reporting (M&R) violation if:
• You fail to take a sample;
• You do not sample at the required number of locations;
• You fail to monitor when your monitoring plan calls for monitoring; or,
• You do not report your results to the State on time.
If you discover that you have violated the Stage 2 DBPR, you should call your primacy agency to discuss the situation (see Appendix C for
contact information). Although you are ultimately responsible for resolving any violations or compliance problems, your State may work with
you to determine the best way to correct the violation and create a long-term compliance solution. If you are a consecutive system, you may
also want to work with your wholesale system to lower DBF levels in your system.
Compliance assistance information and technical advice is available to help small
systems understand and meet their requirements. In addition, EPA has established
compliance assistance centers to serve over a million small businesses. For more
information on these and other programs for small businesses, please contact the
Small Business Ombudsman Clearinghouse/Hotline at (800)368-5888 (or [202] 566-
2822 from the Washington, DC metropolitan calling area). You may also want to look at
the following Web sites for more information:
• Technical Assistance Center Network: http://wwww.tacnet.info
• National Drinking Water Clearinghouse: http://www.nesc.wvu.edu/ndwc/
• Rural Community Assistance Partnership: http://www.rcap.org/resources/
waterlinks.html
30
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Y,*U
Recall that under the Stage 2 DBPR, the MCLs are 0.080 mg/LTTHM and 0.060 mg/L HAAS, based on a locational running annual average
(LRAA) calculation. This means that the MCLs must be met at each monitoring site.
Recall that the compliance dates for the revised MCLs for TTHM and HAAS are based on whether your system is part of a combined distri-
bution system:
• If your system is part of a combined distribution system, you must comply with the revised MCLs by the same date as required for the
largest system in your combined distribution system.
• If your system is not part of a combined distribution system, compliance dates are based on the population served by your system. If
you are a small system that serves less than 10,000 people, you are on schedule 4.
See the compliance schedule on page 6 to determine the date you must start to comply with the Stage 2 MCLs.
You should immediately begin to make sure you can meet the revised MCLs by your
compliance date. If your system's TTHM or HAAS levels exceed the Stage 2 DBPR
MCLs, you may need several years to make the necessary changes to be able to
comply. The best way to evaluate compliance is to conduct a self-audit prior to the
compliance date. Since all non-consecutive (and some consecutive) small systems
are already monitoring under the Stage 1 DBPR, you may have TTHM and HAAS data
to evaluate if you will have compliance issues.
31
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To assess whether you have high levels of DBFs, ask yourself:
1. What are the TTHM and HAAS LRAAs at each sampling point?
- Look at monitoring results from Stage 1 DBPR and your IDSE, if you were required to do one.
- Calculate the LRAA at each monitoring site (you may want to refer to the planning worksheets in step 4 or your IDSE report).
- Take additional samples, if necessary.
- Be aware that a single sample may not provide you with enough information to determine if your system will exceed the MCLs.
2. What is the risk that your TTHM and HAAS levels could exceed the Stage 2 DBPR MCLs?
— TTHM and HAAS levels can vary from sample to sample.
— You may want to give yourself a margin of safety to assure compliance with the TTHM and HAAS MCLs. As a rule of thumb, some
systems plan for TTHM and HAAS LRAAs to be below the MCLs to account for seasonal, year-to-year, source water, and treatment
variability.
32
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STEP #8 - If a Problem Exists, What are my Options?
If TTHM and/or HAAS levels in your system are too high, you may need to make some adjustments, such as:
• Make operational improvements in the treatment train or distribution system.
• Upgrade or install new treatment technology.
• Work with your wholesale system (if you are a consecutive system).
• Partner with other water systems.
• Change source water.
Operational Improvements
There are several treatment and operational
factors that affect DBF formation. Major factors
that affect DBF formation are listed in the table to
the right. By making adjustments to your current
operations, you may be able to reduce levels of
DBFs in your systems. More information on
operational improvements to reduce DBF levels
can be found in the following guidance manuals
(see Appendix B for instructions on how to get
copies):
• Microbial and Disinfection Byproduct Rules
Simultaneous Compliance Guidance Manual
(EPA815-R-99-015, August 1999).
• Simultaneous Compliance Guidance Manual
(EPA-817-D-06-003, June 2006).
• Enhanced Coagulation and Enhanced Precipi-
tative Softening Guidance Manual (EPA-815-R-
99-012, May 1999) (forSubpart H systems that
use conventional filtration).
• Alternative Disinfectants and Oxidants Guidance Manual (EPA-815-R-99-014, April 1999).
Factor
Disinfectant
dose and
residual
concentration
Contact time and
mixing
conditions
Concentration of
DBP precursors
Relationship
In general, the more disinfectant that is
added and the earlier in the treatment
process it is added, the higher the levels
of DBFs formed.
Dose has a greater impact during primary
disinfection than secondary infection.
The longer the contact time between the
disinfectant and NOM, the greater the
amount of DBPs that can be formed.
High TTHM values usually occur where
water age is the oldest.
High HAAS values usually occur where
water age is old and disinfectant residual
is low but present.
Greater DBP levels are formed in waters
with higher concentrations of TOC.
Possible Improvement
You may be able to better control the
amount of disinfectant you add either at
the plant or at booster stations. However,
it is important to balance your
disinfection needs to control microbial
pathogens with the risk of forming DBPs.
Regularly flushing your system or
adjusting operations of storage tanks
can help reduce water age and may
lower levels of TTHMs and HAAS.
Adjust current treatment practices to
remove more TOC prior to disinfection
33
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-D?
You may need to change treatment to reduce formation of TTHM and HAAS to below the MCLs if more cost-effective alternatives are not available.
You should contact your State if you plan to modify your disinfection system or change your treatment process to ensure the modifications or
new treatment will meet the
State's requirements.
Technologies Likely to be Used by Small
Systems
• Chloramination
• Ultraviolet Light (UV)
• Granular Activated Carbon Adsorption with at least
20 minutes of empty bed contact time and an
annual average reactivation/replacement frequency
no greater than 240 days(GAC 20) (BAT)
For the Stage 2 DBPR, EPA has
identified best available technolo-
gies (BATs) for reducing TTHM
and HAAS in drinking water. BATs
are technologies that have
proven effective for reducing
levels of TTHM and HAAS. You
are not required to use any
specific technology. You can use
any State-approved technology
as long as you meet all drinking
water standards. Installing a BAT
makes a system eligible for a general variance if, due to source water conditions, the system cannot achieve compliance. A general vari-
ance, if approved by the State, would allow the system to supply water with TTHM and HAAS levels above the MCLs for a certain period of
time.
EPA anticipates that most small systems that are required to make treatment changes will use chloramines, ultraviolet light (UV), or granular
activated carbon (as GAC 20) to comply with the Stage 2 DBPR. Short descriptions of each of these technologies are given below. For more
information on these and other technologies available to comply with the Stage 2 DBPR and the LT2ESWTR, see the Simultaneous Compli-
ance Guidance Manual. See Appendix B for instructions on how to get a copy and for a list of other technical resources.
Other Technologies
• Granular Activated Carbon Adsorption with at least
10 minutes of empty bed contact time and an
annual average reactivation/replacement frequency
nogreaterthan 120 days (GAC 10) plus enhanced
coagulation or softening (BAT)
• Nanofiltration (BAT)
• Microfiltration and Ultrafiltration
• Ozone
• Chlorine Dioxide
• Membranes
One of the least expensive methods for controlling DBP formation is the use of monochloramine, instead of free chlorine, to maintain a
disinfectant residual in the distribution system. After the appropriate free chlorine contact time for source water primary disinfection, ammo-
nia is added to form chloramine and to slow DBP formation. This reduces the free chlorine contact time and, thus, DBP formation, without
compromising microbial protection. The initial free chlorine contact time and chloramine together provide sufficient disinfection.
34
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The formation of DBFs resulting from chloramination is influenced by the following treatment variables:
• Contact time and chloramine dosage.
• Point of ammonia application.
• pH and temperature.
• Total organic carbon.
• Chlorine-to-ammonia ratio.
• Mixing and reaction time for chloramine formation.
For more information on chloramines and other alternative disinfectants, see the Alternative Disinfectants and Oxidants Guidance Manual.
(See Appendix B for instructions on how to get a copy.)
The use of UV light for disinfection of drinking water has recently received much attention because of
new developments regarding Cryptosporidium inactivation at low UV light doses and because it creates
very few DBFs. Disinfection is accomplished by irradiating water with UV light. However, UV does not
provide any residual disinfectants, so you may be required to use chlorine or chloramine in addition to
UV. For more information, see the Ultraviolet Disinfection Guidance Manual, (see Appendix B for instruc-
tions on how to get a copy.)
Removal of TOC from water supplies can be achieved through adsorption onto solids. Granular Activated Carbon (GAC) is used in water
treatment to adsorb a variety of organic and inorganic compounds. The BATs for the Stage 2 DBPR include two design options for GAC
operational parameters, which are optimized for DBF precursor removal:
1. GAC adsorbers with at least 10 minutes of empty bed contact time and an annual average reactivation/replacement frequency no
greater than 120 days, plus enhanced coagulation or enhanced softening (for subpart H systems with conventional filtration).
2. GAC adsorbers with at least 20 minutes of empty bed contact time and an annual average reactivation/replacement frequency no
greater than 240 days. Small systems may find this option more affordable because of the longer replacement interval.
For more information on GAC, see the Simultaneous Compliance Guidance Manual.
35
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Small consecutive systems may have difficulty remaining in compliance, especially if the finished water delivered by the wholesale system is
near the MCL. If this is true for your system, you should work with your wholesale system to identify the best ways to meet TTHM and HAAS
MCLs in your distribution system. You may want to form a contract with your wholesale system that addresses both finished water quantity
and quality issues, such as meeting all primary drinking water standards or delivering water that is some amount below the DBF MCLs. You
should also evaluate what you can do within your own distribution system to control DBF formation.
Note: Under the Stage 2 DBPR, your system is ultimately responsible for assuring that TTHM and HAAS levels are below the MCLs in your
distribution system.
Small water systems face many of the same technical problems larger systems face,
but they often lack the financial resources or technical expertise. Working with other
water systems may allow you to lower costs, simplify management, and provide your
customers with safe drinking water. By reducing costs and the administrative burden
of compliance, forming partnerships may enable you to comply more easily with the
revised MCL than if you "go it alone."
There are several ways to form partnerships to receive some or all of your water,
including:
1. Cooperative Management. Small systems isolated from other systems cannot
physically interconnect, but they can share management, operators, and technical
staff. They may also form bulk-purchasing agreements. Sharing staff may enable
systems to use operators and engineers who have the expertise to adjust the
treatment trains to ensure compliance. In addition, the money saved by sharing
staff and buying supplies in bulk may help systems be able to afford other neces-
sary compliance measures like new treatment technologies.
2. Joining with one or more communities to form a consolidated system. Two or
more systems can physically interconnect to form a larger system.
3. Purchasing water from another established water system (and becoming a
consecutive system). If your water source or treatment facility is inadequate, you
may want to purchase water from a neighboring system that has a history of
providing safe water.
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If TOC or bromide levels are high in your existing water source, you
may want to consider blending water from a source with lower levels
of these DBF precursors with your current source. Having lower
TOC and bromide in your source water may help you comply with
the TTHM and HAAS MCLs. Generally, groundwater sources have
lower levels of TOC than surface water.
An alternative to blending source water is abandoning your source
and developing a new one. Developing a new water source is expen-
sive, but this may be the most cost-effective way to lower TTHM and
HAAS levels in the long run. Remember that a new water source
may have lower levels of DBF precursors, but higher levels of other
contaminants.
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Modifying or installing treatment, consolidating with another water system, and developing a new water source can be
expensive. System improvements can be funded by raising rates, issuing bonds, or by successfully applying for loans or
grants. The tables below provide information on some programs that may provide financial assistance to help you comply
with the Stage 2 DBPR.
Major Providers of Financial Assistance to Drinking Water Systems
Name of Program
Drinking Water State Revolving
Fund (DWSRF)
Rural Utilities Service (RUS)
Water and Waste Disposal Loan
and Grant Program
State-specific Programs
Tribal-specific Programs
Description
The DWSRF makes low-interest and interest-free loans to water systems
to finance infrastructure improvements. States can "set aside" funds from
their annual EPA grant to provide technical assistance to small systems.
This program offers loans and grants to rural areas to develop water and
waste-disposal systems and to reduce the user costs of these systems.
Your State may offer additional funding programs.
EPA makes direct grants (not loans) to Tribes through the DWSRF Tribal
Set-Aside Program for improvements to water systems that serve Tribes.
States and the Indian Health Service may provide additional financial
assistance.
Contact Information
www.epa.gov/safewater/dwsrf/
contacts.html
Safe Drinking Water Hotline at
1-800-426-4791
www.usda.gove/rus/water/stat
es/usamap.htm
(202) 720-9540
See Appendix C
See Appendix C
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Other Potential Sources of Financing or Financial Assistance to Drinking Water Systems
Name of Program
Community Development Block Grants
(CDBG)
Public Works and Infrastructure
Development Grants
National Bank for Cooperatives Loan
Program (CoBank)
Rural Community Assistance
Corporation (RCAC)
Description
This program offers grants to disadvantaged cities, urban counties, and
states to develop viable urban communities.
These grants help distressed communities overcome barriers that inhibit the
growth of their local economies.
CoBank provides loans to larger, creditworthy and rural utilities
RCAC provides loans to rural utilities in 11 western states to help meet the
financing needs of rural communities and disadvantaged populations
Contact Information
www.hud.gov/offices/cpd/communitydevelopment/
programs/stateadmin/stateadmincontact.cfm
(202)708-1112
wwwdoc.gov/eda/HTML/1 c regloffices.htm
(202) 482-5081
www.cobank.com
(800) 542-8072
www.rcac.org/programs/serv-financial.html
(916)447-2854
for to
Systems should start planning now to meet the MCLs as LRAAs. Some systems having difficulty meeting the LRAAs may need extra time to
comply. States may grant up to an additional 24 months for compliance with the MCLs and operational evaluation levels to systems that
require capital improvements to meet the MCLs.
Your system should start planning now to meet the revised MCL. Some systems having difficulty meeting the revised MCL may need extra time
to comply. States may grant exemptions to eligible systems of any size that cannot comply with the revised MCL by their compliance deadline.
An exemption provides a system with 3 additional years to comply with the revised MCL, while continuing to protect public health. If your system
serves fewer than 3,300 people, the initial exemption may be extended. At the end of the exemption period, your system must be in compliance
with the MCLs for the Stage 2 DBPR.
Systems should request an exemption from their State as soon as they determine that compliance by their required deadline is not feasible. If granted
an exemption, the State will establish a compliance schedule that allows the system time to secure financing and implement a compliance strategy.
Systems must meet certain criteria to be eligible for an exemption. Check with your State to see if you are eligible. In addition, a system still
must be taking all practicable steps to meet the revised MCL, and either must: (1) need capital improvements that cannot be completed before
the compliance deadline; (2) need financial assistance to complete capital improvements that will not be available by the compliance deadline
but is reasonably likely to be available during the exemption; or (3) have agreed to become part of a regional PWS. More information about
exemptions can be found at http://www.epa.gov/safewater/standard/ve-fs.html.
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APPENDIX A: Glossary of Terms Used in this Guide
Community water system means a public water system which serves at 15 service connections used by year-round residents or regularly
serves at least 25 year round residents.
Consecutive systems include all systems that buy or otherwise receive some or all of their finished water from another public water sys-
tem on a regular basis.
Combined distribution system the interconnected distribution system consisting of the distribution systems of wholesale systems and of
the consecutive systems that receive finished water from those wholesale system(s)
Finished water is water that has been introduced into the distribution system of a public water system and is intended for distribution and
consumption without further treatment, except as necessary to maintain water quality in the distribution system (e.g., booster disinfection,
addition of corrosion control chemicals).
Ground water under the direct influence of surface water (GWUDI) means any water beneath the surface of the ground with significant
occurrence of insects or other macroorganisms, algae, or large-diameter pathogens such as Giardia lamblia or Cryptosporidium or signifi-
cant and relatively rapid shifts in water characterisitics such as turbidity, temperature, conductivity, or pH which closely correlate to climato-
logical or surface water conditions. States were required to determine whether ground water was under the influence of surface water for all
systems by 1999.
Haloacetic acids (five) (HAAS) means the sum of the concentrations in milligrams per liter of the haloacetic acid compounds
(monochloroacetic acid, dichloroacetic acid, trichloroacetic acid, monobromoacetic acid, and dibromoacetic acid), rounded to two significant
figures after addition.
Non-transient non-community water systems (NTNCWSs) include all systems (regardless of ownership) that are not CWSs and that
regularly serve at least 25 of the same people for more than 6 months of the year.
Primacy agency is the agency with primary enforcement authority for the Safe Drinking Water Act. Primacy agency is referred to as the
"State" in this document but this also refers to EPA and any tribal government for systems that have one of them as a primacy agency.
Subpart H system is a public water system serving surface water or ground water under the influence of surface water. These systems are
subject to the filtration and disinfection requirements of 40 CFR Subpart H.
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Total Organic Carbon (TOC) means total organic carbon in mg/L measured using heat, oxygen, ultraviolet irradiation, chemical oxidants,
or combinations of these oxidants that convert organic carbon to carbon dioxide, rounded to two significant figures.
UV disinfection is a disinfection process exposing the water supply to ultraviolet light (irradiation) to provide pathogen inactivation.
Wholesale system is a public water system that treats source water as necessary and then delivers finished water to another public water
system. Delivery may be through a direct connection or through the distribution system of another consecutive system.
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EPA has developed a series of guidance manuals to support the Stage 2 Disinfectants and Disinfection Byproducts Rule.
These manuals will aid you, EPA, and State agencies in implementing the rule, and will help to ensure that
implementation is consistent.
• Stage 2 Disinfectants and Disinfection Byproducts Rule (71 FR 388, January 4, 2006)
• Initial Distribution System Evaluation Guidance Manual (EPA-815-B-06-002, January 2006)
• Initial Distribution System Evaluation Guide for Systems Serving <10,000 (EPA-815-B-06-001, January 2006)
• Operational Evaluation Guidance Manual (coming soon)
• Microbial and Disinfection Byproduct Rules Simultaneous Compliance Guidance Manual (EPA-815-R-99-015, August
1999)
• Simultaneous Compliance Guidance Manual for the Long Term 2 and Stage 2 DBP Rules (EPA-817-D-06-003, June
2006)
• Consecutive Systems Guidance Manual (coming soon)
• Stage 2 DBPR Implementation Guidance (EPA-816-R-06-002, June 2006)
• Alternative Disinfectants and Oxidants Guidance Manual (EPA-815-R-99-014, April 1999)
• Enhanced Coagulation and Enhanced Precipitative Softening Guidance Manual (EPA-815-R-99-012, May 1999)
• Ultraviolet Disinfection Guidance Manual (EPA-R-06-007, November 2006)
• Quick Reference Guides (EPA-816-F-06-001 to 004 for all four schedules, June 2006)
To obtain a copy of these manuals or for technical assistance:
• Visit the Stage 2 DBPR website at: http://www.epa.gov/safewater/stage2/index.html
• Visit the Microbial and Disinfection Byproduct Rules website at: http://www.epa.gov/safewater/mdbp/implement.html
• Call the Safe Drinking Water Hotline at 1 -800-426-4791.
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State Contact Information
Alabama
Department of Environmental Management: Water Division
Alaska
Department of Environmental Conservation: Drinking Water Program
American Samoa
Environmental Protection Agency: American Samoa
Arizona
Department of Environmental Quality: Drinking Water Monitoring and
Assessment Division
Arkansas
Department of Health and Human Services: Division of Engineering
California
Department of Health Services: Division of Drinking Water and
Environmental Management
Colorado
Department of Public Health and Environment: Drinking Water Program
Connecticut
Department of Public Health: Drinking Water Division
Delaware
Delaware Health and Social Services: Division of Public Health
District of Columbia
Environmental Protection Agency: Mid-Atlantic Drinking Water
Florida
Department of Environmental Protection: Drinking Water Program
Georgia
Department of Natural Resources: Water Resources Branch
Website
www.adem.state.al.us/WaterDivisionA/VaterDivisionPP.htm
www.state.ak.us/dec/eh/dw/index.htm
www.epa.gov/Region9/cross_pr/islands/samoa.html
www.adeq. state. az.us/environ/water/dw/index. html
www.healthyarkansas.com/eng/index.html
www.dhs.ca.gov/ps/ddwem/
www. cdphe. state. co. us/wq/wq horn. asp
www.dph.state.ct.us/BRS/water/dwd.htm
www.state.de. us/dhss/dph
www.epa.gov/reg3wapd/drinkingwater/
www.dep.state.fl.us/water/drinkingwater/index.htm
www.gaepd.org/Documents/index_water_wrb.html
Phone Number
(334)271-7823
(907) 269-7647
(415)972-3767
(602) 771-2303
(501)661-2623
(916)449-5577
(303) 692-3500
(860) 509-7333
(302) 744-4700
(215)814-5806
(850) 245-8624
(404) 656-4807
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State Contact Information
Guam
Environmental Protection Agency: Guam
Hawaii
Department of Health: Environmental Management Division
Idaho
Department of Environmental Quality: Water Quality Division
Illinois
Environmental Protection Agency: Division of Public Water Supply
Indiana
Department of Environmental Management: Drinking Water Branch
Iowa
Department of Natural Resources: Water Supply Sections
Kansas
Department of Health and Environment: Public Water Supply Section
Kentucky
Department for Environmental Protection: Drinking Water Branch
Louisiana
Department of Health and Hospitals: Division of Environmental and
Health Services
Maine
Department of Health and Human Services: Division of Environmental
Health
Maryland
Department of the Environment: Water Programs
Massachusetts
Department of Environmental Protection: Drinking Water Program
Michigan
Department of Environmental Quality: Water Bureau
Web site
www.epa.gov/region09/cross_pr/islands/guam.html
www. hawai i .gov/health/envi ronmental/water/sdwb/i ndex. html
www.deq.state.id.us/water/prog_issues.cfm
www. epa .state . i 1 . us/wate r/i nd ex-pws .html
www.ai.org/idem/owm/dwb/index.html
www.iowadnr.com/water/drinking/index.html
www.kdhe.state.ks.us/pws/
www.water.ky.gov/dw/
www.oph.dhh.state.la.us/engineerservice/safewater/index.html
www.maine.gov/dhhs/eng/water/index.htm
www.mde.state.md.us/Programs/WaterPrograms/index.asp
www.mass.gov/dep/water/drinking.htm
www.michigan.gov/deq
Phone Number
(415)972-3770
(808) 586-4258
(208) 373-0502
(217)785-8653
(317)232-8603
(515)725-0275
(785) 296-5503
(502)564-3410
(225) 765-5038
(207) 287-2070
(410)537-3000
(617)292-5770
(517)335-4176
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State Contact Information
Minnesota
Department of Health: Drinking Water Protection Section
Mississippi
Department of Health: Water Supply Division
Missouri
Department of Natural Resources: Water Protection Program
Montana
Department of Environmental Quality: Public Water Supply Section
Nebraska
Health and Human Services System: Department of Regulation and
Licensure
Nevada
Health Division: Bureau of Health Protection Services
New Hampshire
Department of Environmental Services: Water Supply Engineering Bureau
New Jersey
Department of Environmental Protection: Water Supply Administration
New Mexico
Environment Department: Drinking Water Bureau
New York
Department of Health: Drinking Water Protection Program
North Carolina
Department of Environment and Natural Resources: Public Water Supply
Section
North Dakota
Department of Health: Division of Municipal Facilities
Ohio
Environmental Protection Agency: Division of Drinking and Ground Waters
Web site
www.health.state.mn.us/divs/eh/water/index.html
www.msdh.state.ms.us/msdhsite/index.cfm
www.dnr.state.mo.us/wpscd/wpcp/index.html
www.deq.mt.gov/wqinfo/pws/index.asp
www.hhs.state.ne.us/enh/enhindex.htm
www.health2k.state.nv.us/BHPS
www.des.state.nh.us/wseb/
www.state.nj.us/dep/watersupply/safedrnk.htm
www.nmenv.state.nm.us/dwb/dwbtop.html
www.health.state.ny.us/nysdoh/water/main.htm
www.deh.enr.state.nc. us/pws
www.health.state.nd.us/mf/
www.epa.state.oh.us/ddagw/
Phone Number
(651)215-0770
(601)576-7518
(573)751-5331
(406) 444-3080
(402)471-2541
(775) 687-6353
(603)271-2513
(609) 292-5550
(505) 476-8625
(518)402-7650
(919)733-2321
(701)328-5211
(614)644-2752
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State Contact Information
Oklahoma
Department of Environmental Quality: Water Quality Division
Oregon
Department of Human Services: Drinking Water Program
Pennsylvania
Department of Environmental Protection: Office of Water Management
Puerto Rico
Department of Health: Public Water Supply Supervision Program
Rhode Island
Department of Health: Office of Drinking Water Quality
South Carolina
Department of Health and Environmental Control: Bureau of Water
South Dakota
Department of Environment and Natural Resources: Drinking Water Program
Tennessee
Department of Environment and Conservation: Division of Water Supply
Texas
Texas Commission on Environmental Quality: Water Supply Division
Utah
Department of Environmental Quality: Division of Drinking Water
Vermont
Department of Environmental Conservation: Water Supply Division
Virgin Islands
Department of Planning and Natural Resources: Division of Environmental
Protection
Web site
www.deq.state.ok.us/WQDnew/index.htm
oregon.gov/DHS/ph/dwp/index.shtml
www.dep.state.pa. us/dep/deputate/watermgt/wsnV
wsm.htm
www.epa.gov/region02/cepd/prlink.htm
www.health.ri.gov/environmental/dwq/index.php
www.scdhec.net/water/index.html
www.state.sd. us/denr/des/drinking/dwprg. htm
www.state.tn.us/environment/dws/
www.tceq .state .tx. us/s ubject/s ubject_water. html
www.drinkingwater.utah.gov
www.vermontdri nki ngwater.org
www.epa.gov/region02/cepd/vilink.htm
Phone Number
(405)702-8100
(971)673-0405
(717)787-5017
(787) 977-5870
(401)222-6867
(803) 898-4300
(605) 773-3754
(615)532-0191
(512)239-4691
(801)536-4200
(802)241-3400
(340)773-1082
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State Contact Information
Virginia
Department of Health: Office of Drinking Water
Washington
Department of Health: Office of Drinking Water
West Virginia
Department of Health and Human Resources: Environmental Engineering
Division
Wisconsin
Department of Natural Resources: Bureau of Drinking Water and
Groundwater
Wyoming
EPA Region 8: Wyoming Drinking Water Program
Web site
www. vd h.state .va . us/dw
www.doh.wa.gov/ehp/dw/
www.wvdhhr.org/oehs/eed/
www.dnr.state.wi. us/org/water/dwg/index.htm
www.epa.gov/region08/water/dwhome/wycoiYwycon.ltml
Phone Number
(804) 864-7500
(360)236-3100
(304)558-6715
(608) 266-6669
(303)312-6312
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US EPA Headquarters
American Indian Environmental Office
www.epa.gov/indian
(202) 564-0303
US EPA Tribal Coordinators
EPA Region 1
EPA Region 2
EPA Region 4
EPA Region 5
EPA Region 6
EPA Region 7
EPA Region 8
EPA Region 9
EPA Region 10
www.epa.gov/region01/govt/tribes/index.html
www.epa.gov/region02/nations/index.html
www.epa.gov/region04/ead/indian/index.htm
www.epa.gov/region5/water/stpb
www.epa.gov/region06/6xa/tribal.htm
www.epa.gov/region07/government_tribal/index.htm
www.epa.gov/region08/tribes
www.epa.gov/region09/cross_pr/indian/index.html
yosemite.epa.gov/r10/tribal.NSF
(888) 372-7341
(212)637-3000
(404) 562-6939
(312)353-2123
(800) 887-6063
(913)551-7003
(303)312-6312
(415)947-8704
(206)553-4011
Other Contacts
Administration for Native Americans
Bureau of Indian Affairs
Indian Health Service
Native American Water Association
www.acf.dhhs.gov/programs/ana/
www.doi.gov/bureau-indian-affairs.html
www.ihs.gov
www.nawainc.org
(877) 922-9262
(202)208-3710
(301)443-3024
(775) 782-6636
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This guide is one in a series of Simple Tools for Effective Performance (STEP) documents for small drinking water
systems. Several other available STEP Guides are listed below. To obtain currently available STEP documents or to
check on the availability of documents listed as under development, call the Safe Drinking Water Hotline at 1-800-426-
4791 or go to http://www.epa.gov/safewater/smallsys/ssinfo.htm.
A Small Systems Guide to the Total Coliform Rule
Publication number: EPA 816-R-01-017A, June 2001
http://www.epa.gov/safewater/smallsys/small-tcr.pdf
Complying with the Revised Drinking Water Standard
for Arsenic
Publication number: EPA 816-R-02-008A, August 2002
http://www.epa. gov/safewater/arsenic/pdfs/ars_f inal_app_f.pdf
Complying with the Stage 1 Disinfectants and
Disinfection Byproducts Rule: Basic Guide
(This guide also includes supplements A and B)
Publication number: EPA816-B-05-004, March 2006
http://www.epa. gov/safewater/mdbp/pdfs/guide_stage1 _basic_final.pdf
Small Systems Guide to Safe Drinking Water
Regulations
Publication number: EPA 816-R-03-017, September 2003
http://www.epa.gov/safewater/smallsys/pdfs/guide_smallsystems_sdwa.pdf
Strategic Planning: A handbook for small water
systems
Publication number: EPA 816-R-02-005, September 2003
http://www.epa.gov/safewater/smallsys/pdfs/guide_smallsystems_stra tplan.pdf
Asset Management: A handbook for small water
systems
Publication number: EPA 816-K-02-006, September 2003
http://www.epa.gov/safewater/smallsys/pdfs/guide_smallsystems_asset_mgmnt.pdf
Sources of Technical and Financial Assistance
Publication number: EPA 816-K-02-005, July 2002
http://www.epa.gov/safewater/smallsys/pdfs/tfa_sdws.pdf
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