,\ ,.
PRIMACY AGENCY
0
DATA ENTRY
INSTRUCTIONS, WITH
EXAMPLES, FOR
STAGE 1 DISINFECTANTS
AND DISINFECTION
BYPRODUCTS RULE
(STAGE 1 DBPR)
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Office of Water (4606M)
EPA816-R-02-012
www.epa.gov/safewater
January 2003 Printed on Recycled Paper
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This document does not substitute for EPA regulation
nor is this document regulation itself. Thus, it cannot
impose legally-binding requirements on EPA, States
(Primacy Agencies), or the regulated community, and its
examples may not apply to a particular situation based
upon the particular circumstances.
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Table of Contents
List of Tables iii
List of Exhibits v
List of Examples vii
Acronyms & Abbreviations ix
Section 1 Introduction
Introduction 1
1.1 What is the purpose of this Guidance Document? 1
1.2 How is this document organized? 1
1.3 What is the benefit of the Stage 1 DBPR? 1
1.4 What is the general applicability of the Stage 1 DBPR? 2
1.5 What is SDWIS and how does it work? 2
1.6 How is this document used? 3
Section 2 Violation Reporting
Violation Reporting 1
2.1 MCL Violations 16
2.1.1 Type 02/1009: Chlorite MCL Violation 18
2.1.2 Type 02/1011: Bromate MCL Violation 26
2.1.3 Type 02/2456: HAAS (Five Haloacetic Acids) MCL Violation 39
2.1.4 Type 02/2950: TTHM (Total Trihalomethanes) MCL Violation 46
2.2 MRDL Violations 50
2.2.1 Type 11/0999: Chlorine MRDL Violation 52
2.2.2 Type 11/1006: Chloramines MRDL Violation 58
2.2.3 Type 11/1008: Chlorine Dioxide MRDL Violation 63
2.3 Treatment Technique Violations 69
2.3.1 Type 12/0400: Qualified Operator in Charge 69
2.3.2 Type 37/0400: Unapproved Treatment Modifications TT Violation .. 71
2.3.3 Type 46/2920: DBF Precursors Removal TT Violation 73
2.4 Monitoring & Reporting Violations 80
2.4.1 Type 27/0400: Monitoring Plan Development and Submittal M&R
Violation 80
2.4.1.1 Failure to Develop Monitoring Plan within 30 days of
Compliance Date M&R Violation 81
2.4.1.2 Failure to Submit Monitoring Plan to Primacy Agency M&R
Violation 83
2.4.2 Type 27/0999: Chlorine Monitoring and Reporting Violation 86
Stage 1 DBPR Reporting Guidance i January 2003
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2.4.3 Type 27/1011: Bromate M&R Violation 91
2.4.4 Type 27/1006: Chloramines M&R Violation 96
2.4.5 Type 27/1009: Chlorite M&R Violation 100
2.4.6 Type 27/1008: Chlorine Dioxide M&R Violation 105
2.4.7 Type 27/2456: HAAS M&R Violation and Type 27/2950: TTHM M&R
Violation 109
2.4.7.1 Subpart H at Least 10,000 People 109
2.4.7.2 Subpart H 500 to 9,999 People 114
2.4.7.3 Subpart H <500 People 117
2.4.7.4 GW at least 10,000 People 117
2.4.7.5 GW< 10,000 People 117
2.4.8 Type 27/2920: Source and Finished Water TOC / Source Water
Monitoring Alkalinity 118
Section 3 General SDWIS Reporting
General SDWIS Reporting 1
3.1 Federally Reported Violations 1
Section 4 Additional Sources of Information
Additional Sources for Technical Information on the Stage 1 DBPR 1
January 2003 ii Stage 1 DBPR Reporting Guidance
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List of Tables
Table 1-1. Regulated Contaminants/Disinfectants 1-2
Table 2.1a. Summary of Stage 1 DBPR Violations 2-2
Table 2.1b: Reporting Fields for Stage 1 DBPR Violations 2-9
Table 2-2. SDWIS/FED Codes for MCL Reporting Under the Stage 1 DBPR 2-17
Table 2-3. Chlorite MCL Violations 2-18
Table 2-4. System A Monitoring Summary 2-19
Table 2-5. System A March 2002 Chlorite Monitoring Results 2-20
Table 2-6. Chlorite Reporting Requirement [40 CFR 141.134] 2-21
Table 2-7. System A April 2002 Chlorite Monitoring Results 2-22
Table 2-8. System A August 2002 Chlorite Monitoring Results 2-24
Table 2-9. System A September 2002 Chlorite Monitoring Results 2-25
Table 2-10. Bromate MCL Violation 2-26
Table 2-1 la. System B (Source # 1) Monitoring Summary 2-28
Table 2-1 Ib. System B (Source # 2) Monitoring Summary 2-29
Table 2-12. System B 1st Quarter 2004 Bromate Monitoring Results 2-30
Table 2-13. Bromate Reporting Requirement [40 CFR 141.134] 2-30
Table 2-14. System B 2nd Quarter 2004 Bromate Monitoring Results 2-31
Table 2-15. System B 4th Quarter 2004 Bromate Monitoring Results 2-33
Table 2-16. System BRAA Bromate Monitoring Results 2-35
Table 2-17. System B June 2005 RAA Bromate Monitoring Results 2-36
Table 2-18. System B2006 RAA Bromate Monitoring Results 2-38
Table 2-19. HAAS MCL Violation 2-39
Table 2-20. System C Monitoring Summary 2-40
Table 2-21. System C 1st Quarter 2002 HAAS Monitoring Results 2-41
Table 2-22. TTHM and HAAS Reporting Requirement [40 CFR 141.134] 2-41
Table 2-23. System C 2002 HAAS Monitoring Results 2-42
Table 2-24. System C 2nd Quarter 2003 HAAS Monitoring Results 2-44
Table 2-25. System C 2nd Quarter 2003 HAAS RAA Monitoring Results 2-45
Table 2-26. TTHM MCL Violation 2-46
Table 2-27. System D Monitoring Summary 2-47
Table 2-28. System D 1st Quarter 2004 TTHM Monitoring Results 2-48
Table 2-29. System D 2004 TTHM Monitoring Results 2-49
Table 2-30. Regulated DisinfectantMRDLs 2-50
Table 2-31. SDWIS/FED Codes for MRDL Reporting Under the Stage 1 DBPR 2-52
Table 2-32. Chlorine MRDL Violation 2-52
Table 2-33. System E Monitoring Summary 2-53
Table 2-34. System E 1st Quarter 2004 Chlorine Residual Monitoring Results 2-54
Table 2-35. Chlorine or Chlorarrines Reporting Requirement [40 CFR 141.134] 2-54
Table 2-36. System E 3rd Quarter 2004 Chlorine Residual Monitoring Results 2-55
Table 2-37. System E4th Quarter 2004 Chlorine Residual Results 2-56
Table 2-38. Chloramines MRDL Violation 2-58
Table 2-39. System F Monitoring Summary 2-59
Table 2-40. System F 2002 Chloramine Monitoring Results 2-60
Stage 1 DBPR Reporting Guidance iii January 2003
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Table 2-41. System F Chloramine Monitoring RAA Results 2-61
Table 2-42. Chlorine Dioxide MRDL Violations 2-63
Table 2-43. System AA Chlorine Dioxide Monitoring Summary 2-64
Table 2-44. System AA January 2002 Chlorine Dioxide Monitoring Results (mg/L) 2-66
Table 2-45. Chlorine Dioxide Reporting Requirement [40 CFR 141.134] 2-67
Table 2-46. SDWIS/FED Codes for TT Reporting Under the Stage 1 DBPR 2-69
Table 2-47. Qualified Operator TT Violation 2-69
Table 2-48. DBPP Removal Treatment Technique Violation 2-73
Table 2-49. System DD's Monitoring Summary 2-75
Table 2-50. Step 1 Required Removal of TOC by Enhanced Coagulation and Enhanced Softening for
Subpart H Systems Using Conventional Treatment 2-76
Table 2-51. System DD2001 Source and Treated Water TOC Monitoring Results 2-76
Table 2-52. System DD2002 Source and Treated Water TOC Monitoring Results 2-78
Table 2-53. System DD DBPR Removal (TT) Reporting Requirements [40 CFR 141.134] 2-79
Table 2-54. SDWIS/FED Codes for Federal Reporting Under the Stage 1 DBPR 2-80
Table 2-55. Monitoring Plan Monitoring and Reporting Violation 2-81
Table 2-56. System EE Monitoring Summary 2-82
Table 2-57. Monitoring Plan - Monitoring and Reporting Violation 2-83
Table 2-58. System FF Monitoring Summary 2-84
Table 2-59. Chlorine Monitoring and Reporting Violation 2-86
Table 2-60. System G Monitoring Summary 2-87
Table 2-61. Bromate Monitoring and Reporting Violation 2-91
Table 2-62. System H Monitoring Summary 2-92
Table 2-63. System H 2004 Treated Water Bromate and Source Water Bromide Monitoring Results
(mg/L) 2-93
Table 2-64. System H 2005 Treated Water Bromate and Source Water Bromide Monitoring Results
(mg/L) 2-95
Table 2-65. Chloramines Monitoring and Reporting Violation 2-96
Table 2-66. System J Monitoring Summary 2-97
Table 2-67. System J 2004 Chloramine Monitoring Results - mg/L as C12 2-97
Table 2-68. System J 2005 Chloramine Monitoring Results - mg/L as C12 2-98
Table 2-69. Chlorite Monitoring and Reporting Violation 2-100
Table 2-70. System GG Monitoring Summary 2-102
Table 2-71. System GG January 2002 Chlorite Monitoring Results (mg/L) 2-103
Table 2-72. Chlorine Dioxide Monitoring and Reporting Violation 2-105
Table 2-73. System HH Monitoring Summary 2-106
Table 2-74. March 2004 Chlorine Dioxide Monitoring Results mg/L as C1O2 2-107
Table 2-75. HAAS Monitoring and Reporting Violation 2-109
Table 2-76. TTHM Monitoring and Reporting Violation 2-109
Table 2-77. System JJ Monitoring Summary 2-110
Table 2-78. System JJ 2002 TTHM & HAAS Monitoring Results (mg/L) 2-112
Table 2-79. System JJ 2003 TTHM & HAAS Monitoring Results (mg/L) 2-112
Table 2-80. System KK 2004 HAAS and TTHM Monitoring Results (mg/L) 2-115
Table 2-81. Paired TOC and Alkalinity Monitoring and Reporting Violation 2-118
Table 2-82. System QQ 2002 TOC and Alkalinity (mg/L) 2-119
January 2003
Stage 1 DBPR Reporting Guidance
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List of Exhibits
Exhibit 2.1 Chlorite MCL Violation Data Element Table and DTP Transactions 2-23
Exhibit 2.2 Chlorite MCL Violation Data Element Table and DTP Transactions 2-25
Exhibit 2.3 Bromate MCL Violation Data Element Table and DTP Transactions 2-32
Exhibit 2.4 Bromate MCL Violation Data Element Table and DTP Transactions 2-34
Exhibit 2.5 Bromate MCL Violation Data Element Table and DTP Transactions 2-37
Exhibit 2.6 HAAS MCL Violation Data Element Table and DTP Transactions 2-43
Exhibit 2.7 TTHM MCL Violation Data Element Table and DTP Transactions 2-50
Exhibit 2.8 Chlorine MRDL Violation Data Element Table and DTP Transactions 2-57
Exhibit 2.9 Chloramine MRDL Violation Data Element Table and DTP Transactions 2-62
Exhibit 2.10 Chlorine Dioxide Acute andNon-Acute MRDL Violation Data Element Table and DTP
Transactions 2-68
Exhibit 2.11 Qualified Operator TT Violation Data Element Table and DTP Transactions 2-71
Exhibit 2.12 Significant Treatment Plant Modification TT Violation Data Element Table and DTP
Transactions 2-73
Exhibit 2.13 Monitoring Plan Monitoring and Reporting Violation and RTC Data Element Table and
DTP Transactions 2-85
Exhibit 2.14 Chlorine Major Monitoring Violation Data Element Table and DTP Transactions .... 2-88
Exhibit 2.15 Chlorine Minor Monitoring Violation Data Element Table and DTP Transactions .... 2-90
Exhibit2.16 Bromate Major Monitoring and Reporting Violation Data Element Table and DTP
Transactions 2-94
Exhibit 2.17 Chloramines Minor Monitoring Violation Data Element Table and DTP Transactions 2-100
Exhibit 2.18 Chlorite M&R Violation Data Element Table and Individual DTP Transactions 2-104
Exhibit 2.19 Chlorine Dioxide M&R Violation Data Element Table and Individual DTP
Transactions 2-108
Exhibit 2.20 TTHM and HAAS M&R Violations Data Element Table and Individual DTP
Transactions 2-116
Exhibit 2.21 TOC/Alkalinity M&R Violations Data Element Table and Individual DTP
Transactions 2-120
Exhibit 3.1 DTP and Transaction Format 3-2
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January 2003 vi Stage 1 DBPR Reporting Guidance
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List of Examples
Example System Description - System A 2-18
Example #1 - No Chlorite MCL Violation with Single Sample >1.0 mg/L 2-20
Example #2 - One Chlorite MCL Violation in a Month 2-21
Example #3 - Multiple Chlorite MCL Violations in a Month 2-23
Example #4 - Routine Daily Monitoring and Routine 3-Sample Set 2-25
Example System Description - System B 2-26
Example #5 - Calculating Bromate Compliance for 1st Quarter During 1st Year of Monitoring 2-29
Example #6 - Calculating Bromate Compliance for 2nd Quarter During 1st Year of Monitoring2-31
Example #7 - Calculating Bromate Compliance Based on a Complete Year of Data 2-32
Example #8 - Calculating RAA for Bromate 2-34
Example #9 - Bromate MCL Exceedance 2-36
Example #10 - CWS Fails to Collect Several Required Bromate Samples 2-37
Example System Description - System C 2-39
Example #11 - HAAS MCL RAA Calculating After 1st Quarter 2-40
Example #12 - HAAS Compliance Calculation During 1st Year of Monitoring 2-42
Example #13 - HAAS MCL Full Year RAA Calculation 2-43
Example# 14 - HAAS Missing Samples 2-44
Example System Description - System D 2-46
Example #15 - TTHM MCL 1st Quarter of Data 2-47
Example #16 - TTHM MCL 3rd Quarter RAA 2-48
Example System Description - System E 2-52
Example #17 - Chlorine MRDL 1st Quarter RAA 2-53
Example #18 - Chlorine MRDL 3rd Quarter 2-55
Example #19 - Chlorine MRDL Full Year RAA 2-56
Example System Description - System F 2-58
Example #20 - Chloramines MRDL Full Year RAA in Compliance 2-59
Example #21 - Chloramines MRDL Full Year RAA in Violation 2-61
Example System Description - System AA 2-63
Example #22 - Chlorine Dioxide MRDL Acute and Non-Acute Violation 2-65
Example System Description - System BB 2-69
Example #23 - Qualified Operator (TT) 2-70
Example System Description - System CC 2-72
Example #24 - Significant Treatment Process Modification Plan (TT) 2-72
Example System Description - System DD 2-74
Example #25 - TT (DBPP Reduction) System Meets Alternative Compliance Criteria 2-76
Example #26 - TT (DBPP Reduction) Failure to Meet Alternative Compliance Criteria .... 2-77
Example System Description- System EE 2-81
Example #27 - M&R Monitoring Plan Compliance by System 2-81
Stage 1 DBPR Reporting Guidance vii January 2003
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Example System Description - System FF 2-83
Example #28 - Failure to Submit a Monitoring Plan 2-83
Example System Description - System G 2-86
Example #29 - M&R for Chlorine Major Violation 2-87
Example #30 - M&R for Chlorine Minor Violation 2-88
Example #31 - M&R forChlorine 2-90
Example System Description - System H 2-91
Example #32 - M&R for Bromate Major Violation 2-93
Example #33 - M&R for Bromate Major Violation Spanning Two Calendar Years 2-95
Example System Description - System J 2-96
Example #34 - M&R for Chloramines Compliance Over 12 Months 2-97
Example #35 - M&R for Chloramines 2-98
Example System Description - System GG 2-101
Example #36 - M&R for Chlorite 2-101
Example System Description - System HH 2-105
Example #37 - M&R forChlorine Dioxide 2-106
Example System Description - System JJ 2-109
Example #38 - M&R TTHM andHAAS Calendar Year 2002 2-110
Example #39 - M&R for HAAS & TTHM 2002 / 2003 2-111
Example #40 - M&R for HAAS & TTHM Calendar Year 2003 2-113
Example System Description - System KK 2-114
Example #41 - M&R for HAAS and TTHM Small System Quarterly 2-114
Example System Description - System QQ 2-118
Example #42 - M&R Paired TOC/Finished Alkalinity 2-118
January 2003 viii Stage 1 DBPR Reporting Guidance
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Acronyms & Abbreviations
ACR:
CCR:
CFR:
CWS:
DBF:
DBPP:
DTP:
EPA:
GWUDI:
HAAS:
IESWTR:
Log:
MCL:
MCLG:
MDBP:
mg/L:
M&R:
MRDL:
MRDLG:
NTNCWS:
PWS:
RAA:
RTC:
SDWA:
SDWIS:
Stage 1 DBPR
Subpart H system:
SUVA:
SWTR:
TOC:
TT:
TTHM:
USEPA:
x log removal:
Annual Compliance Report
Consumer Confidence Report
Code of Federal Regulations
Community Water System
Disinfection Byproducts
Disinfection Byproducts Precursors
Data Transfer File
Environmental Protection Agency
Ground Water Under the Direct Influence of Surface Water
Haloacetic Acids (five) (chloroacetic acid, dichloroacetic acid, trichloroacetic
acid, bromoacetic acid and dibromoacetic acid)
Interim Enhanced Surface Water Treatment Rule
Logarithm (common, base 10)
Maximum Contaminant Level
Maximum Contaminant Level Goal
Microbial and Disinfectants/Disinfection Byproducts
Milligrams per Liter
Monitoring and Reporting
Maximum Residual Disinfectant Level
Maximum Residual Disinfectant Level Goal
Non-Transient Non-Community Water System
Public Water System
Running Annual Average
Return to Compliance
Safe Drinking Water Act, or the "Act," as amended 1996
Safe Drinking Water Information System
Stage 1 Disinfection and Disinfection Byproducts Rule
PWS using surface water or ground water under the direct influence of surface
water
Specific Ultraviolet Absorbance
Surface Water Treatment Rule
Total Organic Carbon
Treatment Technique
Total Trihalomethanes (chloroform, bromodichloromethane,
dibromochloromethane, and bromoform)
United States Environmental Protection Agency
Reduction to 1/10* of original concentration
Stage 1 DBPR Reporting Guidance
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Section 1
Introduction
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Introduction
1.1 What is the purpose of this Guidance Document?
On December 16, 1998, the US Environmental Protection Agency (USEPA) published in the Federal
Register the Stage 1 Disinfectants and Disinfection Byproducts Rule (Stage 1 DBPR). This document is
intended to provide guidance to Primacy Agencies regarding the monitoring and reporting requirements
of the Stage 1 DBPR. It discusses through the use of typical water system examples, the water system
monitoring and reporting requirements, compliance and recordkeeping calculations, systems' non-
compliance information reporting responsibilities, and the Primacy Agency's reporting responsibilities to
EPA's database, the Safe Drinking Water Information System Federal (SDWLS/FED). Using this
reference, Primacy Agencies will be able to identify violations and report appropriate noncompliance
information to EPA. Throughout this document, the term Primacy Agency will be used to refer to a
State, Tribal Government, or EPA Region with primary enforcement authority for the SDWA.
1.2 How is this document organized?
The document includes an Introduction Section 1 and three additional Sections as follows: Section 2
discusses violation determinations and when, where and what to report; Section 3 provides basic
SDWIS/FED reporting information regarding the Stage 1 DBPR, and Section 4 describes additional
sources of information regarding the Stage 1 DBPR. Section 2 is divided into subsections that discuss
Maximum Contaminant Level (MCL) and Maximum Residual Disinfectant Level (MRDL) violations,
Treatment Technique (TT) violations, Monitoring and Reporting (M&R) violations and recordkeeping
violations. Each violation type uses example facility descriptions and the appropriate SDWIS/FED
violation type codes to illustrate the typical violations that may be encountered during the routine
operation of water systems. Example DTP (data transfer file) transactions that Primacy Agencies would
report to EPA, representing the information or violations, are also included.
1.3 What is the benefit of the Stage 1 DBPR?
The Stage 1 DBPR is part of a series of rules, the "Microbial and Disinfection Byproducts Cluster"
(MDBP Cluster), that are intended to control microbial pathogens while minimizing the public health
risks from disinfectants and disinfection byproducts (DBFs). The Stage 1 DBPR specifically addresses
risks associated with disinfectants and DBFs. This rule was published concurrently with the Interim
Enhanced Surface Water Treatment Rule (IESWTR), which addresses control of microbial pathogens in
Subpart H systems.
The Stage 1 DBPR applies to all community water systems and nontransient noncommunity water
systems that add a chemical disinfectant during any part of the treatment process. The Stage 1 DBPR
updates and supersedes the 1979 total trihalomethanes (TTHM) standard by lowering the MCL for
TTHM, establishing new MCLs for chlorite, bromate, and haloacetic acids (HAAS), and establishing
MRDLs for chlorine, chloramines, and chlorine dioxide (see Table 1-1). In addition, the Stage 1 DBPR
requires systems using conventional filtration to comply with a treatment technique requirement for DBP
precursor removal and imposes certain requirements upon transient non-community water systems that
use chlorine dioxide.
The following table presents the Maximum Contaminant Levels (MCLs) and Maximum Residual
Disinfection Levels (MRDLs) prescribed by the rule.
Stage 1 DBPR Reporting Guidance Page 1 - 1 January 2003
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Table 1-1. Regulated Contaminants/Disinfectants
Regulated Contaminants
MCL
(mg/L)
Regulated
Disinfectants
MRDL
(mg/L)
Total Trihalomethanes (TTHM)
0.080
Chloroform
Bromodichloromethane
Dibromochloromethane
Bromoform
Chlorine
4.0 as C12
Five Haloacetic Acids (HAAS)
0.060
Mono chloroac etic Acid
Dichloro acetic Acid
Trichloro acetic Acid
Bromo acetic Acid
Dibromoacetic Acid
Chloramines
Chlorine Dioxide
4.0 as Cl,
Bromate (plants that use ozone)
Chlorite (plants that use chlorine dioxide)
0.010
1.0
mg/L = milligrams/Liter
For more information on the Stage 1 DBPR requirements please call the Safe Drinking Water Hotline (1-
800-4264791) or visit the EPA website at www.epa.gov/safewater.
1.4 What is the general applicability of the Stage 1 DBPR?
The 1979 TTHM requirements applied only to community water systems serving 10,000 or more people.
Under the Stage 1 DBPR, systems that use surface water or ground water under the direct influence of
surface water (GWUDI) as a source (also referred to as Subpart H systems) serving 10,000 or more
people had to comply with the requirements of the Stage 1 DBPR beginning January 1, 2002. Primacy
Agencies can grant up to 24 additional months for capital improvements for Subpart H systems serving
10,000 or more people. This extension delays the compliance date for meeting the MCL, but the system
must monitor as required by the rule and report the results of any detected Stage 1 DBPR contaminants in
their Consumer Confidence Report (CCR). Since the system would not be in violation of the MCL,
public notification would not be required. Additionally, Subpart H systems that serve fewer than 10,000
people, and all affected ground water systems, must comply with the requirements beginning January 1,
2004.
1.5 What is SDWIS and how does it work?
SDWIS/FED (Safe Drinking Water Information System/Federal version) is EPA's national database that
stores routine information about the Nation's drinking water.
Primacy Agencies supervise the drinking water systems within their jurisdictions to implement and
enforce the Safe Drinking Water Act (SDWA). The SDWA requires that Primacy Agencies report
drinking water information periodically to EPA; this information is maintained in SDWIS/FED.
January 2003
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Stage 1 DBPR Reporting Guidance
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Primacy Agencies report the following information to EPA:
1. Basic information on each water system, including: name, PWS-ID number, number of people
served, type of system (year-round or seasonal), source of water (ground water or surface water),
and a description of the treatment processes.
2. Violation information for each water system whether it has followed established monitoring and
reporting schedules, complied with mandated treatment techniques, or violated any MCLs.
3. Enforcement information: what actions Primacy Agencies have taken to ensure that drinking
water systems return to compliance if they are in violation of a drinking water regulation.
4. Monitoring results for unregulated contaminants and for regulated contaminants in certain
instances when the monitoring results exceed the MCL.
EPA uses this information to determine if and when it needs to take action against non-compliant
systems, oversee Primacy Agency drinking water programs, track contaminant levels, respond to public
inquiries, and prepare national reports. EPA also uses this information to evaluate the effectiveness of its
programs and regulations, and to determine whether new regulations are needed to further protect public
health. A subset of the data is posted to EPA's Enviro facts web page for public access.
1.6 How is this document used?
Primacy Agency personnel should evaluate each system for its need to comply with the provisions of the
Stage 1 DBPR. For those systems required to comply with the Stage 1 DBPR, this document evaluates
compliance for each rule requirement (i.e.; required system monitoring, system reporting to the Primacy
Agency, system public notice, and reporting by the Primacy Agency to SDWIS/FED). The descriptions
of the example systems in this document include example monitoring data and the calculations and data
comparisons necessary to determine compliance with the requirements of the Stage 1 DBPR. Example
SDWIS/FED data transfer file (DTP) tables show how the data describing violations of the Stage 1
DBPR are to be encoded to be entered into the SDWIS/FED system In addition, the examples provide
guidance regarding public notification requirements consistent with EPA's Public Notification (PN)
Rule. This guidance document does not offer any examples of SDWIS/FED reporting requirements
associated with water system violations of the PN Rule. Users should refer to the "Final State
Implementation Guidance for the Public Notification Rule" for additional information on these
requirements and reporting to Primacy Agencies and EPA.
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Section 2
Violation Reporting
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Violation Reporting
Violations of the Stage 1 DBPR include maximum contaminant level (MCL) violations, maximum
residual disinfectant level (MRDL) violations, treatment technique (TT) violations, and monitoring and
reporting (M&R) violations. The rule requires sample collection, analysis, reporting, and record keeping
for compliance with four MCLs (chlorite, bromate, TTHM and HAAS), and three MRDLs (chlorine,
chlorine dioxide, and chloramines). Three expressions of TT violations and ten different expressions of
M&R violations are also defined. The violations are summarized in Table 2-la, "Summary of Stage 1
DBPR Violations." Table 2.1b, "Reporting Fields for Stage 1 DBPR," provides guidance about the
violation fields that need to be reported for each of the violations. Additional detailed transaction coding
instructions are contained in the "SDWIS/FED Data Entry Instructions."
Stage 1 DBPR Reporting Guidance Page 2 - 1 January 2003
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Table 2.1a. Summary of Stage 1 DBPR Violations
VIOLATION DEFINITION
DESCRIPTION
MAJOR
MINOR1
VIOLATION
TYPE2
DETAILS
Type 02/1009
For all systems using chlorine
dioxide for disinfection or
oxidation, if the average of any
three-sample set exceeds the
chlorite MCL of 1.0 mg/L.
Report violations on a
monthly basis, with
severity indicated by
the number of
exceedances.
N/A
MCL
Will require a new numeric field (Cl 112) in which to
record the number of times the MCL was exceeded during
the month. EPA will use this number to represent the
actual number of violations incurred by the water system,
for Annual Compliance Report (ACR) and other statistical
purposes.
Type 02/1011
For all systems using ozone for
disinfection or oxidation, if the
running annual average computed
quarterly of available monthly
samples, exceeds the bromate
MCL of 0.010 mg/L.
Quarterly violations of
quarterly duration.
N/A
MCL
Record the begin and end dates of the violation to be the
quarter in which the monthly samples create an annual
average exceeding the standard. If the water system misses
one or more monthly samples, it uses only the values
available to compute compliance. No need to report
analytic result as part of the violation.
Type 02/2456
For all systems, ifthe running
annual average computed quarterly
of available monthly samples
(quarterly averages) exceeds 0.060
mg/L for HAAS.
Quarterly violations of
quarterly duration.
N/A
MCL
Record the begin and end dates of the violation to be the
quarter in which the monthly samples create an annual
average exceeding the standard. Ifthe water system misses
one or more monthly samples, it uses only the values
available to compute compliance. No need to report
analytic result as part of the violation.
Type 02/2950
For all systems, ifthe running
annual average computed quarterly
of available monthly samples
(quarterly averages) exceeds 0.080
mg/L for TTHM.
Quarterly violations of
quarterly duration.
N/A
MCL
Record the begin and end dates of the violation to be the
quarter in which the monthly samples create an annual
average exceeding the standard. Ifthe water system misses
one or more monthly samples, it uses only the values
available to compute compliance. No need to report
analytic result as part of the violation.
January 2003
Page 2 - 2
Stage 1 DBPR Reporting Guidance
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VIOLATION DEFINITION
DESCRIPTION
MAJOR
MINOR1
VIOLATION
TYPE2
DETAILS
Type 11, 13/1008
For all systems using chorine
dioxide for disinfection or
oxidation.
ACUTE (type 13): If any of the
three required chlorine dioxide
distribution samples taken on the
day following a daily entry point
sample MRDL exceedance of 0.8
mg/L also exceed the MRDL; or,
failure to collect and report
additional chlorine dioxide
samples (in the distribution system)
on the day following an MRDL
exceedance. This is specified in the
rule as a MRDL violation.
NON-ACUTE (type 11): If any two
consecutive daily entry point
samples exceed 0.8 mg/L and all
distribution samples are less then
0.8 mg/L; or failure to collect and
report additional chlorine dioxide
samples (at the entry point) on the
day following an MRDL
exceedance at the entrance to the
distribution system is also specified
in the rule as an M RDL vio lation.
Report violations on a
monthly basis, with
severity indicated by
the number of
exceedances that
occurred during that
month.
N/A
MRDL
Will require a new numeric field (Cl 112) in which to
record the number of times the MRDL was exceeded
during the month. EPA will use this number to represent
the actual number of violations incurred by the water
system, for ACR and other statistical purposes.
Water systems can incur acute and nonacute violations, and
have them recorded in SDWIS/FED during the same
month.
Stage 1 DBPR Reporting Guidance
Page 2 - 3
January 2003
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VIOLATION DEFINITION
DESCRIPTION
MAJOR
MINOR1
VIOLATION
TYPE2
DETAILS
Type 11/1006
For all systems using chloramines,
if the running annual average,
computed quarterly, of monthly
averages of avaikble data exceeds
4.0 mg/L of chloramines (unless
increased residual levels in the
distribution system address specific
microbial contamination problems).
Quarterly violations of
quarterly duration.
N/A
MRDL
Record the begin and end dates of the violation to be the
quarter in which the monthly samples create an annual
average exceeding the standard. If the water system misses
one or more monthly samples, it uses only the values
available to compute compliance. No need to report
analytic result as part of the violation.
Type 11/0999
For all systems using chorine, if the
running annual average, computed
quarterly, of monthly averages of
available data exceeds 4.0 mg/L of
chlorine (unless increased residual
levels in the distribution system
address specific microbial
contamination problems).
Quarterly violations of
quarterly duration.
N/A
MRDL
Record the begin and end dates of the violation to be the
quarter in which the monthly samples create an annual
average exceeding the standard. If the water system misses
one or more monthly samples, it uses only the values
available to compute compliance. No need to report
analytic result as part of the violation.
Type 12/0400
Failure to have a State-approved
and listed qualified operator
running the p lant.
Begins: When State
learns that the fac ility
does not have a
qualified operator.
Ends: When the State
is satisfied that the
plant has a qualified
operator.
N/A
TT
Have a future end date = 12/31 /2015, with the end date
modified as a result of a link to anRTC, to be reported
January 2003
Page 2 - 4
Stage 1 DBPR Reporting Guidance
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VIOLATION DEFINITION
DESCRIPTION
MAJOR
MINOR1
VIOLATION
TYPE2
DETAILS
Type 27/1008
Failure to collect and report 100%
of required chlorine dioxide
samples.
Violations reported
monthly with severity
indicated by the
number of days not
sampled or not
reported. All such
violations are
considered major.
major
M&R
Will require a new numeric field (Cl 112) in which to
record the number of days samples were not taken or
reported during the month. EPA will use this number to
represent the actual number of violations incurred by the
water system, for ACR and other statistical purposes.
Type 27/1009
MAJOR: Failure to collect and
report at least 90% of daily chlorite
samples at the entrance to the
distribution system or any required
three-set chlorite sample in the
distribution system.
MINOR: Collecting and reporting
90-99% of daily chlorite samples.
Violations reported
monthly at the system
level.
either
M&R
The major/minor is computed based upon ALL the samples
that are required, for the entire water system
Type 27/0400
Failure to develop, within 3 0 days
of the initial compliance dates, and
monitor in accordance with the
monitoring plan.
Begins: 30 days after
the initial compliance
date (either January
31, 2002 for large
Subpart H systems or
January 31,2004 for
small Subp art H
systems).
Ends: When State is
satisfied that plan has
been developed (date
of report, if available).
major
M&R
Have a future end date (such as 12/31/2015) with the end
date modified as a result of a link to an RTC, to be
reported.
Stage 1 DBPR Reporting Guidance
Page 2 - 5
January 2003
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VIOLATION DEFINITION
DESCRIPTION
MAJOR
MINOR1
VIOLATION
TYPE2
DETAILS
Type 27/0400
Failure to submit a copy of the
monitoring plan to the State no later
than the date of the first report
required u nder §141.134. (Only
Subpart H systems > 3,300
population must submit plan to
state, all must develop one)
Begins: 10 days after
report to be completed
(either April 10,2002
for large Sub part H
systems or April 10,
2004 for small
Subpart H systems).
Ends: When report is
submitted to the State,
if required.
major
M&R
Have a future end date (such as 12/31/2015) with the end
date modified as a result of a link to an RTC, to be
reported.
Type 27/1006
MAJOR: Failure to collect and
report at least 90% of chloramine
samples.
MINOR: Collecting and reporting
90-99% of chloramine samples.
Begins: First day of
the quarter in which
one or more samples
are missed
Ends: Last day of the
quarter in which one
or more samples are
missed
either
M&R
Types 27/1011
Failure to collect and report 100%
of required bromate samples
(I/plant/month for routine and
1/plant/quarter for reduced)
Begins: First day of
the quarter in which
one or more samples
are missed
Ends: Last day of the
quarter in which one
or more samples are
missed
major
M&R
Note: There is no violation for a water systems' failure to
take bromide samples. This failure could result in the
water system having to return to a routine bromate
monitoring schedule.
January 2003
Page 2 - 6
Stage 1 DBPR Reporting Guidance
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VIOLATION DEFINITION
DESCRIPTION
MAJOR
MINOR1
VIOLATION
TYPE2
DETAILS
Type 27/0999
MAJOR: Failure to collect and
report at least 90% of chlorine
samples.
MINOR: Collecting and reporting
90-99% of chlorine samples.
Begins: First day of
the quarter in which
one or more samples
are missed
Ends: Last day of the
quarter in which one
or more samples are
missed
either
M&R
Type 27/2920
Failure to collect source and
finished water TOC samples and
alkalinity sample
(Ipair/plant/month routine or
Ipair/plant/quarter reduced.
Begins: First day of
the quarter in which
one or more samples
are missed
Ends: Last day of the
quarter in which one
or more samples are
missed
major
M&R
Types 27/2456 and 27/2950
MAJOR: Failure to collect and
report at least 90% of required
TTHM and HAAS samples.
MINOR: Collecting and reporting
90-99% of required TTHM and
HAAS samples.
Begins: First day of
the quarter (or annual
or triennial period
begin date) in which
one or more samples
are missed
Ends: Last day of the
quarter (or annual or
triennial perio d begin
date) in which one or
more samples are
missed
either
M&R
For systems on annual and triennial periods, use the begin
date and end date of those periods.
Stage 1 DBPR Reporting Guidance
Page 2 - 7
January 2003
-------
VIOLATION DEFINITION
DESCRIPTION
MAJOR
MINOR1
VIOLATION
TYPE2
DETAILS
Type 37/0400
Failure to sub mil and ob tain State
approval of a plan detailing
significant treatment process
modifications prior to making such
modifications.
Begins: Either date
when mo dification is
begun or when the
State becomes aware
of the modification.
Ends: When State
notifies the facility
that it approves of the
modification.
Major
M&R
Have a future end date (such as 12/31/2015) with the end
date modified as a result of a link to an RTC, to be
reported.
Type 46/2920
Failure to meet the Treatment
Technique requirements for DBF
Precursor removal.
Begins: Beginning of
quarter in which
sampling is
conducted.
Ends: End of quarter
in which samp ling is
conducted.
N/A
TT
Quarterly compliance period
1 column identifies the violation as being "major", eithermajor or minor based upon noncompliance circumstances ("either"), or not applicable to the violation
("N/A")
column identifies the type of violation: MCL = maximum contaminant level; MRDL = Maximum Residual Disinfectant Level; M&R = monitoring and
reporting
January 2003
Page 2 - 8
Stage 1 DBPR Reporting Guidance
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Violation reporting fields
Only the fields identified below in Table 2.1b, "Reporting Fields for Stage 1 DBPR Violations," are to be reported to represent Stage 1 DBPR
violations. Data Transfer File (DTP) capabilities such as qualifiers 1 and 2 (PWS ID and Violation ID, respectively) continue to be required.
Batch Sequence number continues to be optional. All other violation fields shouldNOT be included in submissions to EPA. Those fields, if
included in a submission, will be rejected.
Table 2.1b: Reporting Fields for Stage 1 DBPR Violations
Violation
Type
Contaminant
Code (C1103)
Type
Code
(C1105)
Compliance
Period Begin Date
(C1107)
Compliance Period End
Date (C1109)
Severity
Indicator
count (C1112)1
Major Violation
Indicator
(C1131)
Chlorite
Chlorite
Bromate
MCL
M&R
MCL
1009
1009
1011
02
27
02
first day of month
first day of month
first day of quarter
last day of mo nth
last day of mo nth
last day of quarter
yes
do not report
do not report
do not report
yes= failure to
collect at least
90% o f daily
chlorite samples
or any required 3
sample set in the
distribution
system
np_=failure to
collect/report
90%-99% of
daily chlorite
samples
do not report
Stage 1 DBPR Reporting Guidance
Page 2 - 9
January 2003
-------
Violation
Type
Contaminant
Code (C1103)
Type
Code
(C1105)
Compliance
Period Begin Date
(C1107)
Compliance Period End
Date (C1109)
Severity
Indicator
count (C1112)1
Major Violation
Indicator
(C1131)
Bromate
HAAS
HAAS
TTHM
TTHM
Acute Chlorine
Dioxide
M&R
MCL
M&R
MCL
M&R
MRDL
1011
2456
2456
2950
2950
1008
27
02
27
02
27
13
first day of quarter
first day of quarter
first day of quarter
first day of quarter
first day of quarter
first day of month
last day of quarter
last day of quarter
last day of quarter
last day of quarter
last day of quarter
last day of mo nth
do not report
do not report
do not report
do not report
do not report
yes
yes= failure to
collect at least
90% of required
samples
np_=failure to
collect/report
90%-9 9% of
samples
do not report
yes= failure to
collect at least
90% of required
samples
np_=failure to
collect/report
90%-9 9% of
samples
do not report
yes= failure to
collect at least
90% of required
samples
np_=failure to
collect/report
90%-9 9% of
samples
do not report
January 2003
Page 2 - 10
Stage 1 DBPR Reporting Guidance
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Violation
Type
Contaminant
Code (C1103)
Type
Code
(C1105)
Compliance
Period Begin Date
(C1107)
Compliance Period End
Date (C1109)
Severity
Indicator
count (C1112)1
Major Violation
Indicator
(C1131)
Nonacute Chlorine
Dioxide
Chlorine Dioxide
Chloramine
Chloramine
Chlorine
Chlorine
Failure to have
State approved and
listed qualified
operator running the
plant
MRDL
M&R
MRDL
M&R
MRDL
M&R
TT
1008
1008
1006
1006
0999
0999
0400
11
27
11
27
11
27
12
first day of month
first day of month
first day of quarter
first day of quarter
first day of quarter
first day of quarter
Date State learns
that the facility
does not have a
qualified operator
last day of mo nth
last day of mo nth
last day of quarter
last day of quarter
last day of quarter
last day of quarter
SOW IS/FED will default to
12/31/2015. A State
associating a returned to
compliance enforcement to
this violation will cause
SDWIS/FEDto adjust the
end date to the returned to
compliance date
yes
yes
do not report
do not report
do not report
do not report
do not report
do not report
always major
do not report
yes= failure to
collect at least
90% of required
samples
np_=failure to
collect/report
90%-9 9% of
samples
do not report
yes= failure to
collect at least
90% of required
samples
np_=failure to
collect/report
90%-9 9% of
samples
do not report
Stage 1 DBPR Reporting Guidance
Page 2-11
January 2003
-------
Violation
Type
Contaminant
Code (C1103)
Type
Code
(C1105)
Compliance
Period Begin Date
(C1107)
Compliance Period End
Date (C1109)
Severity
Indicator
count (C1112)1
Major Violation
Indicator
(C1131)
Failure to develop
or submit a
monitoring plan
Failure to collect
source and finished
water TOC samples
and alkalinity
sample
Failure to sub mil
and obtain State
approval of a plan
detailing significant
treatment process
modifications prior
to making such
modifications.
0400
2920
0400
27
27
37
M&R
M&R
M&R
30 days after initial
compliance date
first day of quarter
Either date when
modificatio n is
begun or when the
State becomes
aware of the
modification.
SOW IS/FED will default to
12/31/2015. A State
associating a returned to
compliance enforcement to
this violation will cause
SDWIS/FEDto adjust the
end date to the returned to
compliance date. Returned
to compliance is achieved
when the State is satisfied
that the plan has been
develop ed, submitted or is
being followed, depending
on the nature of the
noncompliance
last day of quarter
SOW IS/FED will default to
12/31/2015. A State
associating a returned to
compliance enforcement to
this violation will cause
SDWIS/FEDto adjust the
end date to the returned to
compliance date. Returned
to compliance is achieved
when the State notifies the
facility that it approves of
the modification.
do not report
do not report
do not report
always major
always major
always major
January 2003
Page 2 - 12
Stage 1 DBPR Reporting Guidance
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Violation
Type
Contaminant
Code (C1103)
Type
Code
(C1105)
Compliance
Period Begin Date
(C1107)
Compliance Period End
Date (C1109)
Severity
Indicator
count (C1112)1
Major Violation
Indicator
(C1131)
Failure to meet the
Treatment
Technique
requirements for
DBF Precursor
removal.
2920
46
TT
First day of quarter
last day of quarter
do not report
do not report
'new numeric field (Cl 112) in which to record the number of times the MCL/MRDL was exceeded, or the number of samples missed during the month. EPA
will use this number to represent the actual number of violations incurred by the water system, for ACR and other statistical purposes.
Stage 1 DBPR Reporting Guidance
Page 2 - 13
January 2003
-------
The following discussions address reporting issues associated with compliance computations and/or
violation reporting time frames. Where the water system either has not had one year of sampling data for
computing the rolling annual average, or does not operate for a full year, the discussions below should
clarify how compliance should be determined under these circumstances. In addition, information
regarding violation dates will be provided where the rule compliance computations cross from one month
to the next (e.g., where a sample taken on the last day of a month requires additional sampling the next
month, and the results indicate noncompliance).
1st Year Running Annual Average Calculations
During the first year of monitoring, water systems cannot compute a complete running annual average
(RAA) since a full year of data is not available. The Stage 1 DBPR states that a water system is out of
compliance during their first year of monitoring if the sample results would cause an RAA to be
exceeded. The following discussion explains how to implement this requirement during the first, second
and third quarters of the first year of compliance.
The following calculations should be used during the first year of compliance monitoring (i.e. the 1st year
the rule is effective, or the 1st year of operation) for the parameters using an RAA for computing
compliance. RAA calculations are used in the compliance-related computations for bromate, HAAS,
TTHM, chloramines, chlorine, and DBF precursors (i.e., TOC removal, Specific Ultraviolet Absorbance
(SUVA), alkalinity and magnesium hardness).
Routine monitoring for bromate, chloramines and chlorine is conducted on a monthly frequency;
compliance calculations are computed quarterly of monthly averages. Each month the average of all
samples taken during that month is calculated. To calculate the RAA for monitoring that is conducted
monthly, first add the monthly results (or averages) from the previous 12 consecutive months and divide
the result by 12. This calculation will be performed at the end of each quarter.
Compliance monitoring for HAAS and TTHM is conducted on a quarterly frequency. Compliance
calculations are computed quarterly of quarterly averages. First, the system will average the results of all
their quarterly samples to obtain the quarterly average. To calculate the RAA for monitoring that is
conducted quarterly, add the results from the previous four consecutive quarters and divide the result by
four.
1st Quarter Computation
For quarterly monitoring parameters, calculate the arithmetic average of the sample results obtained in
the quarter. Since only one quarter's results are available, assume that the results for quarters 2, 3, and 4
are zero. Calculate the sum of the quarterly averages (the actual value from quarter 1 plus zeros from
quarters 2 through 4), and divide the result by 4. If the result (properly rounded) is greater than the MCL
or MRDL, then the water system is in violation of the MCL or MRDL for the 1st quarter.
For monthly monitoring parameters, calculate the arithmetic average of the sample results obtained in
each month. Since after the 1st quarter, only three months of results are available, assume that the results
for the remaining 9 months (quarters 2, 3, and 4) are zeros. Calculate the sum of the monthly averages
(the actual values from the first three months plus zeros for the last nine months), and divide the result by
12. If the result is greater than the MCL or MRDL, then the water system is in violation of the MCL or
MRDL for the 1st quarter.
January 2003 Page 2-14 Stage 1 DBPR Reporting Guidance
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2nd Quarter Computation
For quarterly monitoring parameters, calculate the arithmetic average of the sample results obtained in
the quarters. Since only two quarters' results are available, assume that the results for quarters 3 and 4
are zero. Calculate the sum ofthe quarterly averages (the actual values from quarters 1 and 2 plus zeros
from quarters 3 and 4), and divide the result by 4. If the result is greater than the MCL or MRDL, then
the water system is in violation ofthe MCL or MRDL for the 2nd quarter.
For monthly monitoring parameters, calculate the arithmetic average ofthe sample results obtained in
each month. Since after the 2nd quarter, only six months of results are available, assume that the results
for the remaining 6 months (quarters 3 and 4) are zeros. Calculate the sum ofthe monthly averages (the
actual values from the first six months plus zeros for the last six months), and divide the result by 12. If
the result is greater than the MCL or MRDL, then the water system is in violation ofthe MCL or MRDL
for the 2nd quarter.
3rd Quarter Computation
For quarterly monitoring parameters, calculate the arithmetic average ofthe sample results obtained in
the quarters. Since only three quarters' results are available, assume that the result for quarter 4 is zero.
Calculate the sum of the quarterly averages (the actual value from quarters 1, 2, and 3 plus zero from
quarter 4), and divide the result by 4. If the result is greater than the MCL or MRDL, then the water
system is in violation ofthe MCL or MRDL for the 3rd quarter.
For monthly monitoring parameters, calculate the arithmetic average ofthe sample results obtained in
each month. Since after the 3rd quarter, only nine months of results are available, assume that the results
for the remaining 3 months (quarter 4) are zeros. Calculate the sum ofthe monthly averages (the actual
values from the first nine months plus zeros for the last three months), and divide the result by 12. If the
result is greater than the MCL or MRDL, then the water system is in violation ofthe MCL or MRDL for
the 3rd quarter.
4th Quarter Computation
For quarterly monitoring parameters, calculate the arithmetic average ofthe sample results obtained in
the quarters. Since all the quarters' results are available, calculate the sum ofthe quarterly averages (the
actual values from quarters 1 through 4), and divide the result by 4. If the result is greater than the MCL
or MRDL, then the water system is in violation ofthe MCL or MRDL for the 4th quarter.
For monthly monitoring parameters, calculate the arithmetic average ofthe sample results obtained in
each month. Calculate the sum ofthe monthly averages (the actual values from all twelve months), and
divide the result by 12. If the result is greater than the MCL or MRDL, then the water system is in
violation ofthe MCL or MRDL for the 4th quarter.
Calculating an RAA When There is Data Missing Prior to the Desired Calculation Date
At the end of any monitoring period, when using an RAA in a calculation to define compliance with an
MCL or MRDL, and the system has failed to take all ofthe necessary samples, the system must use the
available data. The system must calculate the RAA by dividing the sum ofthe available data by the
number of samples actually taken. For example, when at the end ofthe 3rd quarter, there is quarterly
monitoring parameter data for only quarters 1 and 3, the system must then calculate a sum ofthe
Stage 1 DBPR Reporting Guidance Page 2-15 January 2003
-------
available data (quarterly averages for quarters 1 and 3) and divide that sum by 2. The result is compared
to the MCL or MRDL to determine compliance.
When at the end of the 3rd quarter (9 months) there is monthly monitoring parameter data for only seven
of the nine months, the system must calculate the sum of the available data (monthly averages for seven
months) and divide the sum by seven. The result is compared to the MCL or MRDL to determine
compliance.
Computing RAAs for Seasonal Water Systems
A water system that operates seasonally must collect samples, have the samples analyzed and report
results during any monitoring period in which it operates. Compliance with an RAA is calculated in any
compliance period by using the data available from the period of operation. For example, if a seasonal
water system operates June through September each year, it must collect samples for the 2nd and 3rd
quarters of each year. It should collect monthly monitoring samples in each of months June, July,
August, and September. During the first year of operation, at the end of the 1st quarter, no RAA
calculation is completed, since the system did not operate. At the end of the 2nd quarter, for quarterly
parameters, the system should divide the quarterly average value by 2 and compare the result to the MCL
or MRDL. For monthly parameters, the system should divide the available monthly average value (June)
by 4 and compare the result to the MCL or MRDL. After the first year of operation, an RAA can be
calculated at the end of each quarter, using the available data from the previous year.
Reporting Violations of RAA
Due to the complexity associated with recording non-compliance dates for MCL's/MRDL's exceeding
standards, EPA has decided to have Primacy Agencies record the quarter in which the sampling results
cause the RAA to be exceeded. If the RAA standard continues to be exceeded in subsequent quarters,
even if the most recent quarter's values are below the standard, the water system remains out of
compliance with the RAA for that quarter and an MCL/MRDL violation for that quarter must be reported
to EPA. This situation will continue until a subsequent quarter's sampling results lead to an RAA that no
longer exceeds the standards. In addition, where compliance sampling crosses from one month or one
quarter to the next, and noncompliance with one or more provisions of the regulations is determined, the
Primacy Agency should use as the basis for deciding the month or quarter for which to report the
violation the date in which monitoring was performed or samples analyzed/reported that made the
Primacy Agency aware that the water system was out of compliance.
Sampling Location and Calculating Compliance
Some parameters can be measured at multiple locations in the distribution system to determine
compliance. The values from these measurements are expressed as an average during a month or quarter.
Other parameters must be measured at the entry point from each source or treatment plant. A careful
determination regarding the correct location or locations for monitoring is necessary for the accurate
calculation of an RAA for compliance purposes.
2.1 MCL Violations
General Discussion of Maximum Contaminant Level Violations
DBP MCL violations are reported to SDWIS/FED when the average of sample results for a contaminant
exceeds its EPA-established MCL. Since all DBP reporting is for sample averages rather than individual
January 2003 Page 2-16 Stage 1 DBPR Reporting Guidance
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results, violation Type "02" ("MCL, Average") is used rather than Type "01" ("MCL, Single Sample").
Table 2-2 presents a summary of the MCL violation reporting codes.
Table 2-2. SDWIS/FED Codes for MCL Reporting Under the Stage 1 DBPR
Violation
Code
02
Contaminant
Code
1009
1011
2456
2950
MCL Violations
Chlorite MCL
Bromate MCL
Haloacetic Acids MCL
Total Trihalomethanes MCL
The MCL for Chlorite
Water systems using chlorine dioxide as a disinfectant or oxidant are required to monitor for chlorite.
Chlorite monitoring consists of taking daily samples at the entrance to the distribution system and one 3-
sample set per month in the distribution system. In addition, systems are required to take one 3-sample
set in the distribution system the day following any day when a routine entrance to the distribution
system sample exceeds the chlorite MCL (1.0 mg/L).
Compliance with the MCL for chlorite is determined by comparing the arithmetic average of each 3-
sample set to the MCL of 1.0 mg/L. A system incurs an MCL violation if the average of a 3-sample set is
greater than 1.0 mg/L. A system can incur multiple chlorite MCL violations in one month if they are
required to collect multiple 3-sample sets.
The MCL for Bromate
Water systems using ozone as a disinfectant or oxidant must perform bromate monitoring. Routine
bromate monitoring consists of collecting one sample per month at the entrance to the distribution system
from each ozone treatment plant. If a system has multiple plants using ozone, then a distinct compliance
determination must be completed for each plant.
Compliance with the MCL for bromate is determined quarterly by comparing the RAA of monthly
sample results (or monthly average for months when more than one sample per plant is taken) to the
MCL of 0.010 mg/L. Compliance is determined per plant. Therefore, if the bromate RAA from an ozone
treatment plant exceeds the MCL, then the system incurs a single MCL violation.
The MCLs for TTHM and HAAS
Systems using chlorine and/or chloramines are required to take TTHM and HAAS samples in their
distribution systems at the point of maximum residence time and at other predetermined sites, depending
on the population the system serves.
Compliance with the MCLs for TTHM and HAAS is determined quarterly by comparing the RAA of
quarterly average concentrations to the MCL. The MCL for TTHM is 0.080 mg/L and the MCL for
HAAS is 0.060 mg/L. An RAA of the quarterly averages that is greater than the MCL is a single
violation of that MCL for the system
Stage 1 DBPR Reporting Guidance Page 2-17 January 2003
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2.1.1 Type 02/1009: Chlorite MCL Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, page II-4 & II-5
Section IV-D, page 27
Appendix D, Attachment 6
Cross-reference to Rule:
40CFR141.133(b)(3)
Table 2-3. Chlorite
Violation
Code
02
Contaminant
Code
1009
MCL Violations
Violation Description
The arithmetic average of any required 3-sample set exceeds the
l.Omg/L.
MCL of
Example System Description - System A
System A is a large Subpart H community water system that serves 11,500 people. The system treats
surface water from a river with a conventional filtration plant. Chlorine dioxide is used for taste and
odor control and as a primary disinfectant. Chlorine is used as a residual disinfectant in the distribution
system. The system has no other sources or treatment plants. Water system monitoring must be
performed in accordance with items identified in Table 2.4. For the purposes of this example, only
chlorite MCL issues will be discussed.
System A Summary
Population Served: 11,500
Source #1: Surface Water
Treatment #1: Conventional filtration,
chlorine dioxide, chlorine
January 2003 Page 2-18 Stage 1 DBPR Reporting Guidance
-------
Table 2-4. System A Monitoring Summary
PARAMETER
OR
TASK
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distribution
System
Distribution
System
Daily Monthly
Quarterly Annually or
less than
annually
Disinfectants
Chlorine / Chloramines
Chlorine Dioxide
X
X
X
X
X1
A 3-sample set must be collected in the distribution
system the day folbwing any daily sample that exceeds
of 0.8 mg/L at the entrance to the distribution system
DBFs
TTHM /HAAS
Chlorite (grab)
(3-sample set)
(3-sample set)
X
X
X
X
X
X
X
A 3-sample set must be collected in the distribution
system the day following any daily sample that exceeds
1.0 mg/L at the entrance to the distributi on system
DBF Precursor
Paired TOC
Alkalinity (as CaCO3)
SUVA2
Magnesium Hardness2
(as CaCO3)
X
X
X
Monitoring Plan YES NO SUBI
DTrrVFTTDTTr* TC\ T
X | , SPEC
X
X
X
VIIT MONITORING PLAN
'RIMACY AGENCY BY
:iFIC DATE
YES NO
III II
ll x
1 Same date, location and time as total coliform are taken
2 Optional -Alternative compliance criteria of40 CFR141.135
System A is a large (> 10,000 people) Subpart H system that must meet the requirements of Stage 1
DBPR beginning January 1,2002. System A's certified operator collects and analyzes grab samples for
chlorite on a daily basis at the entrance to the distribution system. Samples are collected at the locations
and according to the schedule specified in the provisions of the monitoring plan, and must be analyzed by
a certified laboratory. The operator records the results on a chlorite monitoring form each day and
compares the result each day to the 1.0 mg/L level specified for additional chlorite monitoring. If the
daily sample is greater than 1.0 mg/L then System A must collect a 3-sample set in the distribution
system the following day. Once a month a 3-sample set for chlorite is collected and analyzed. The 3-
Stage 1 DBPR Reporting Guidance
Page 2-19
January 2003
-------
sample set is composed of one grab sample near the 1st customer, one grab sample at a location in the
distribution system representative of the average system retention time, and one grab sample at a location
in the distribution system representative of the maximum system retention time. The locations and
results of the analysis of the 3-sample set are recorded on the chlorite monitoring form. The operator
calculates the arithmetic average of the results of the 3-sample set, and records that average on the
chlorite monitoring form. The operator then compares the results of the 3-sample set average to the
chlorite MCL of 1.0 mg/L.
A violation of the MCL for chlorite is defined as any arithmetic average of a 3 -sample set that exceeds
the 1.0 mg/L MCL established for chlorite. Please refer to Section 2.4.5 for a discussion of chlorite
monitoring and reporting violations.
Example #1 - No Chlorite MCL Violation with Single Sample >1.0 mg/L
Table 2-5 summarizes the chlorite monitoring results from March 2002. System A's operator collects the
daily entry point to the distribution system grab samples for chlorite on days 1 through 12, and none of
the measurements is greater than 1.0 mg/L. On day 13, chlorite is measured at 1.3 mg/L at the entrance
to the distribution system As required on the following day (day 14) a 3-sample set is collected in
addition to the daily distribution system entrance sample. The day 14 entrance sample result is 0.9 mg/L
and the arithmetic average of the samples taken for the 3-sample set is 0.9 mg/L. The daily distribution
system entrance samples are collected on days 15 thru 31, and none of the values exceeds 1.0 mg/L.
Table 2-5. System A March 2002 Chlorite Monitoring Results
Day
1-12
13
14
15-31
Result
(mg/L)
< 1.0
1.3
0.9
< 1.0
>1.0
mg/L?
N
Y
N
N
3-Sample Set
NA
Required on day
14
0.8,0.9, 1.0
NA
Arithmetic Average of 3-
sample set
-
-
0.9
-
MCL Violation
No
No
No
No
Example #1 Decision
System A is in compliance with the chlorite MCL. Since the arithmetic average of the 3-sample set taken
on day 14 does not exceed the MCL of 1.0 mg/L, System A is in compliance with the Stage 1 DBPR for
chlorite during March 2002. Please note that the 3-sample set collected on day 14 also satisfies the
monthly 3-sample set requirement.
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System A is in compliance with the Stage 1 DBPR for chlorite, the system must routinely
report the information included in Table 2-6 to the Primacy Agency.
January 2003
Page 2 - 20
Stage 1 DBPR Reporting Guidance
-------
Table 2-6. Chlorite Reporting Requirement [40 CFR 141.134]
For water systems
monitoring for
chlorite under the
requirements of
40 CFR141.132(b)
Systems required to sample quarterly or more frequently must report to the Primacy
Agency within 10 days after the end of each quarter in which samples are collected.
The water system must report to the Primacy Agency:
(1) The number of entry point samples taken each month for the last three months
(2) The location, date and result of each sample (both entry point and distribution
system) taken during the last quarter
(3) For each month in the reporting period, the arithmetic average of all samples
taken in each 3-sample set taken in the distribution system
(4) Whether, based upon §141 .133(b)(3), the MCL was violated, in which
month, and how many times it was violated in each month.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Example #2 - One Chlorite MCL Violation in a Month
Table 2-7 summarizes the chlorite monitoring results from April, 2002. System A's operator collects the
daily distribution system entrance grab sample for chlorite on days 1 through 4, and none of the
measurements exceeds 1.0 mg/L. On day 5 she collects the daily entrance sample and the value is 1.1
mg/L. On day 6 the operator collects the daily entrance grab sample and the required 3-sample set. The
entrance grab sample measurement is 0.9 mg/L and the arithmetic average from the 3-sample set is 0.8
mg/L chlorite. On days 7 through 20, none of the daily entrance measurements exceeds 1.0 mg/L. On
day 21, the daily measurement is 1.4 mg/L. On day 22, the daily measurement is 1.4 mg/L and the
arithmetic average of the 3-sample set is 1.3 mg/L. On day 23, the daily sample is 1.0 mg/L and the
arithmetic average of the 3-sample set is 0.9 mg/L. On days 24 through 30 none of the daily
measurements exceeds 1.0 mg/L chlorite.
Stage 1 DBPR Reporting Guidance Page 2-21 January 2003
-------
Table 2-7. System A April 2002 Chlorite Monitoring Results
Day
1-4
5
6
7-20
21
22
23
24-30
Result
(mg/L)
< 1.0
1.1
0.9
< 1.0
1.4
1.4
1.0
< 1.0
>1.0
mg/L?
N
Y
N
N
Y
Y
N
N
3-Sample Set
NA
Required day 6
0.9, 0.8, 0.7
NA
Required day 22
Required day 23
(1.2, 1.3, 1.4)
0.8,0.9, 1.0
NA
Arithmetic Average of 3-
sample set
--
--
0.8
--
--
1.3
0.9
--
MCL Violation
No
No
No
No
No
Yes
No
No
Example #2 Decision
System A is in violation of the chlorite MCL for the month of April 2002. The system violated the MCL
on day 22, the day when the arithmetic average of the required 3-sample set exceeded the MCL of 1.0
mg/L. The operator reports that the chlorite MCL was violated one time in April 2002.
Public Notice Requirements
System A must provide Tier 2 public notice of the MCL violation according to the requirements of 40
CFR141.201.
System Reporting Requirements
The reporting requirements for chlorite are summarized in Table 2-6.
Primacy Agency to SDWIS/FED Reporting
The Primacy Agency must report one chlorite MCL violation to SDWIS/FED. When this type of
violation occurs, the Primacy Agency must use a severity indicator to report the number of times during
the month that the MCL violation occurred. Regardless of how many violations occur in one month, a
single violation is reported to EPA, with the number of MCL violations recorded in the field called
"Severity Indicator Count" (Cl 112). SDWIS Reporting Code: 02/1009.
The appropriate SDWIS/FED chlorite MCL violation data elements and individual DTP transactions are
listed below in Exhibit 2.1.
January 2003
Page 2 - 22
Stage 1 DBPR Reporting Guidance
-------
Data Elements:
Number Name Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C 1 1 03 Contaminant Code 1009
C 1 1 05 Violation Type Code 02
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be one month later than C1107
Cl 1 12 Severity Indicator Count Number of times the MCL is violated
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234573
GA1234573
GA1234573
GA1234573
GA1234573
12-18
0200001
0200001
0200001
0200001
0200001
19-25
26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1112
32-71
1009
02
20020401
20020430
1
72-74
75-80
Exhibit 2.1 Chlorite MCL Violation Data Element Table and DTF Transactions
Example #3 - Multiple Chlorite MCL Violations in a Month
Table 2-8 summarizes the chlorite monitoring results for August 2002. System A's operator collects the
daily entrance grab sample for chlorite on days 1 through 5, and none of the measurements exceeds 1.0
mg/L. On day 6, she collects the daily entrance sample and the value is 1.2 mg/L. On day 7, she collects
the entrance grab sample and the required 3-sample set. The entrance grab sample measurement is 0.9
mg/L and the arithmetic average from the 3-sample set is 0.9 mg/L chlorite. On days 8 through 13, none
of the daily measurements exceeds 1.0 mg/L. On day 14, the daily measurement is 1.4 mg/L. On day 15,
the daily measurement is 1.3 mg/L and the arithmetic average of the required 3-sample set is 1.2 mg/L.
On day 16, the daily sample is 1.1 mg/L and the arithmetic average of the 3-sample set is 1.1 mg/L. A 3-
sample set is required on Day 17. On day 17, neither the daily sample nor the 3-sample set exceeds 1.0
mg/L. On days 18 through 31, none of the daily measurements exceeds 1.0 mg/L chlorite.
Stage 1 DBPR Reporting Guidance
Page 2 - 23
January 2003
-------
Table 2-8. System A August 2002 Chlorite Monitoring Results
Day
1-5
6
7
8- 13
14
15
16
17
18-31
Result
(mg/L)
< 1.0
1.2
0.9
< 1.0
1.4
1.3
1.1
0.8
< 1.0
>1.0
mg/L?
NO
YES
NO
NO
YES
YES
YES
NO
NO
3-Sample Set
NA
Required Day 7
0.8,0.9, 1.0
NA
Required Day 1 5
Required Day 16
1.1, 1.2, 1.3
Required Day 17
1.0, 1.1, 1.2
0.6, 0.7, 0.8
NO
Arithmetic Average of 3-
sample set (mg/L)
NA
NA
Avg = 0.9
NA
NA
Avg= 1.2
Avg= 1.1
Avg = 0.7
NA
MCL Violation ?
NA
NO
NO
NO
NO
YES
YES
NO
NO
Example #3 Decision
System A violated the chlorite MCL two times in the month of August, 2002. The violations occurred on
day 15 and day 16, when the arithmetic average of the required 3-sample set exceeded the MCL of 1.0
mg/L.
Public Notice Requirements
System A must provide Tier 2 Public notice of the MCL violations according to the requirements of 40
CFR141.201.
System Reporting Requirements
The reporting requirements for chlorite are summarized in Table 2-6.
Primacy Agency to SDWIS/FED Reporting
The Primacy Agency must report the chlorite MCL violations to SDWIS/FED. It must report that the
MCL was violated two times during the month of August 2002. The Primacy Agency is not required to
report either the exact dates within the month of August 2002 when the MCL was violated, or specific
analytical data regarding the MCL violations, only that the MCL was violated two times during the
month. When this type of violation occurs, the Primacy Agency must use a severity indicator to report
the number of times during the month that the MCL violation occurred. Regardless of how many
violations occur in one month, a single violation DTP transaction is reported to EPA, with the number of
MCL violations recorded in the field called "Severity Indicator Count" (Cl 112). SDWISReporting
Code: 02/1009.
The appropriate SDWIS/FED chlorite MCL violation data elements and individual DTP transactions are
listed below in Exhibit 2.2.
January 2003
Page 2 - 24
Stage 1 DBPR Reporting Guidance
-------
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C 1 1 03 Contaminant Code 1009
C1105 Violation Type Code 02
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be one month later than C1107
Cl 1 12 Severity Indicator Count Number of times the MCL is violated
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234573
GA1234573
GA1234573
GA1234573
GA1234573
12-18
0200001
0200001
0200001
0200001
0200001
19-25
26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1112
32-71
1009
02
20020801
20020831
2
72-74
75-80
Exhibit 2.2 Chlorite MCL Violation Data Element Table and DTF Transactions
Example #4 - Routine Daily Monitoring and Routine 3-Sample Set
Table 2-9 summarizes the chlorite monitoring results for September, 2002. System A's operator collects
the daily entrance sample on days 1 thru 29 and none of the measurements is greater than 1.0 mg/L. On
day 30, in addition to the daily distribution system entrance sample, the required monthly 3-sample set is
collected. The daily sample result is 0.8 mg/L and the arithmetic average of the samples taken for the 3-
sample set is 0.9 mg/L.
Table 2-9. System A September 2002 Chlorite Monitoring Results
Day
1-29
30
Result
(mg/L)
< 1.0
0.8
>1.0
mg/L?
NO
NO
3-Sample Set
NA
0.7,0.9, 1.1
Arithmetic Average of 3-
sample set (mg/L)
NA
Avg = 0.9
MCL Violation ?
NO
NO
Example #4 Decision
System A is in compliance with the chlorite MCL for September 2002 since the arithmetic average of the
routine 3-sample set did not exceed the chlorite MCL of 1.0 mg/L.
Stage 1 DBPR Reporting Guidance
Page 2 - 25
January 2003
-------
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System A is in compliance with the Stage 1 DBPR for chlorite, the system must routinely
report the information included in Table 2-6 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
2.1.2 Type 02/1011: Bromate MCL Violation
Cross-reference to Stage 1 DBPR Implementation Guidance:
Section II, page II-4 & II-5
Section IV-D, page 26
Appendix D, Attachment 7
Cross-reference to Rule:
40CFR141.133(b)(2)
Table 2-10. Bromate MCL Violation
Violation
Code
02
Contaminant
Code
1011
Violation Description
A violation occurs when the running annual arithmetic average computed
quarterly of monthly samples, or for months in which the system takes more
than one sample, the average of all samples taken during the month exceeds
the MCLofO.OlOmg/L.
Note: See Section 2 for a discussion of calculating the RAA for the 1s year of operation.
Example System Description - System B
System B is a small Subpart H community water system that serves 8,000 people. The system has a
conventional treatment plant using water from a river that experiences high turbidity and high total
organic carbon (TOC) readings. The system uses ozone for disinfection and oxidation on a routine basis
and also adds chlorine to the water entering the clearwell.
In addition to the surface water source, System B has a series of wells that are connected by manifold at a
treatment facility where all the water is treated for removal of iron and manganese. Ozone is used as an
oxidant for the dissolved metals and chlorine is added as a secondary disinfectant. The system, therefore,
utilizes two ozone treatment plants and the water is introduced into the distribution system at two entry
points.
System B Summary
January 2003
Page 2 - 26
Stage 1 DBPR Reporting Guidance
-------
Population Served: 8,000
Source #1: Surface water
Treatment #1: Conventional filtration, ozone, chlorine
Source #2: Ground water (seasonal use)
Treatment #2: Ozone, chlorine, filtration for iron removal
System B, as a Subpart H system that serves fewer than 10,000 people, must meet the requirements of
Stage 1 DBPR beginning January 1, 2004. The Stage 1 DBPR requires any system utilizing ozone to
comply with the MCL and monitoring requirements for bromate (a DBP of ozone). System B must
collect and analyze one grab sample for bromate during each month at the entrance to the distribution
system from each ozone plant. The certified operator collects the bromate samples during times when
the ozonation systems are operating under normal conditions at the locations and according to the
schedule specified in the monitoring plan. Bromate samples must be analyzed by a certified laboratory.
Water system monitoring must be performed in accordance with Tables 2-1 la and 2-1 Ib.
Stage 1 DBPR Reporting Guidance Page 2 - 27 January 2003
-------
Table 2-lla. System B (Source # 1) Monitoring Summary
PARAMETER
OR TASK
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant Entrance to Distribution Daily Monthly Quarterly Annually or
Distribution System less than
System annually
Disinfectants:
Chlorine / Chloramines
X
X1
DBPs:
TTHM /HAAS
Bromate
X
X
X
X
DBP Precursors:
Paired TOC
Alkalinity (as CaCO3)
SUVA*
Bromide**
Monitoring Plan
REQUIRED
X
X
X
X(source)
YES NO SUB]
mlO J
| || SPE(
X
X
X
X
MIT MONITORING PLAN
PRIMACY AGENCY BY
:iFIC DATE
YES
x
NO
* Optional -Alternative compliance criteria of40 CFR141.135
** Optional for reduced bromate monitoring
1 Same date, location and time as total coliform are taken
January 2003
Page 2 - 28
Stage 1 DBPR Reporting Guidance
-------
Table 2-llb. System B (Source # 2) Monitoring Summary
PARAMETER
OR TASK
Disinfectants:
SAMPLE LOCATION
Plant Entrance to Distribution
Distribution System
System
SAMPLE FREQUENCY
Daily
Monthly Quarterly
Annually or
less than
annually
Chlorine / Chloramines
DBPs:
X
X1
TTHM /HAAS
Bromate
X
X
X
X
DBP Precursors:
Paired TOC
Alkalinity (as CaCO3)
SUVA*
Bromide**
Monitoring Plan
REQUIRED
X
X
X
X(source)
YES NO SUB]
rTO ]
SPEC
X
X
X
X
MIT MONITORING PLAN
PRIMACY AGENCY BY
:iFIC DATE
YES
X
NO
* Optional -Alternative compliance criteria requirement of 40 CFR141.135
** Optional for reduced bromate monitoring
1 Same date, location and time as total coliform are taken
Example #5 - Calculating Bromate Compliance for 1^ Quarter During 1st Year of Monitoring
Table 2-12 summarizes the bromate monitoring results for the first quarter of 2004. In January,
February, and March 2004, System B's operator collects the grab samples for bromate at the entrance to
the distribution system from both ozone plant 1 and ozone plant 2. He records the results on the bromate
monitoring form. On March 31,2004, when the 1st quarter of the calendar year is over, he calculates, for
each ozonation plant, the average of the monthly January 2004, February 2004 and March 2004 samples.
He assumes that the remaining nine months of the 1st year are zero, and he divides the 1st quarter average
of the available monthly bromate concentrations forplant 1 (0.025 mg/L) and the average of the monthly
concentrations for plant 2 (0.010 mg/L) by 12.
Example #5 Decision
System B is in compliance with the bromate MCL during the 1st quarter of 2004 (January, February, and
March, 2004). Since System B has not completed a full year of bromate monitoring, the operator cannot
calculate compliance with the bromate MCL using an RAA. The 1st year RAA calculation methodology
must be used. For each plant that the sum of the available monthly bromate monitoring average values
Stage 1 DBPR Reporting Guidance
Page 2 - 29
January 2003
-------
must be calculated, bromate concentrations of 0 mg/L are assumed for any months in the year for which
monitoring has not yet occurred, and the sum is divided by twelve for comparison to the MCL. See
Section 2 for a full discussion of 1st year RAA calculation methodology.
Table 2-12. System B 1st Quarter 2004 Bromate Monitoring Results
Month Plant #1 (mg/L) Plant #2 (mg/L)
January 0.028 0.014
February 0.020 0.009
March 0.027 0.007
2nd Quarter1
3rd Quarter1
4th Quarter1
Compliance
Calculation
Sum
-12
0.075
0.00625
0.030
0.0025
Ql RAA 0.006 < 0.010 0.003 < 0.010
1 To calculate compliance for the 1st quarter, assume the results for 2nd, 3rd, and 4th quarters are zero. See Section 2
for a detailed discussion on calculating the RAA during the first year on monitoring.
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System B is in compliance with the bromate MCL, it must routinely report the following
information to the Primacy Agency.
Table 2-13. Bromate Reporting Requirement [40 CFR 141.134]
For water systems
monitoring for
bromate under the
requirements of
40 CFR141.132(b)
Systems required to sample quarterly or more frequently must report to the Primacy
Agency within 10 days after the end of each quarter in which samples are collected.
The water system must report to the Primacy Agency:
(1) The number of samples taken during the last quarter
(2) The location, date and result of each sample taken during the last quarter
(3) The arithmetic average of the monthly arithmetic average of all samples taken
in the last year
(4) Whether, based on §141.133(b)(2), the MCL was violated
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
January 2003
Page 2 - 30
Stage 1 DBPR Reporting Guidance
-------
Example #6 - Calculating Bromate Compliance for 2^ Quarter During 1st Year of Monitoring
Table 2-14 summarizes the bromate monitoring results for the 2nd quarter of 2004. In April, May and
June of 2004, System B's operator collects the grab samples for bromate at the entrance to the
distribution system from both ozone plant 1 and ozone plant 2. He records the results on the bromate
monitoring form. On June 30, 2004, when the 2nd quarter of the calendar year is over, he calculates the
monthly averages of the samples for each ozonation plant. He records the 2nd quarter monthly average
bromate concentration values on the bromate monitoring form.
Table 2-14. System B 2nd Quarter 2004 Bromate Monitoring Results
Month Plant #1 Distribution System Plant #2 Distribution System
Entrance Result (mg/L) Entrance Result (mg/L)
1st Quarter 0.028,0.020,0.027 0.014,0.009,0.007
2ndQuarter 0.018,0.028,0.020 0.006,0.015,0.009
3rd Quarter1
4th Quarter1
Compliance Sum 0.141 0.060
Calculation
-12 0.01175 = 0.012 0.005
2nd Quarter RAA 0.012 > 0.010 0.005 < 0.010
1 To calculate compliance for the 2nd quarter, assume the results for the 3rd and 4th quarters are zero. See Section 2
for a detailed discussion on calculating the RAA during the first year of monitoring.
Example #6 Decision
System B is in violation of the bromate MCL for the 2nd quarter of 2004. In addition, System B will be in
violation of the bromate MCL for the 3rd and 4th quarters of 2004 as well, regardless of the bromate
concentrations measured during those quarters. System B's operator must report a violation of the
bromate MCL because of the results for ozonation plant 1. The system has not completed a full year of
bromate monitoring, but the sum of the available monthly bromate concentrations plus concentrations of
0 mg/L for the months for which monitoring has not yet occurred divided by twelve already exceeds the
bromate MCL (0.010 mg/L).
Public Notice Requirements
System B must provide Tier 2 public notice of this MCL violation according to the requirements of 40
CFR141.201.
System Reporting Requirements
The reporting requirements for bromate are summarized in Table 2-13.
Primacy Agency to SDWIS/FED Reporting
A violation is reported for the entire water system, even though only one treatment plant was found to be
out of compliance. Primacy Agencies should provide the compliance period begin and end dates, but
Stage 1 DBPR Reporting Guidance Page 2-31 January 2003
-------
should not provide an analytic result to SDWIS as part of the report of a bromate violation. SDWIS
Reporting Code 02/1011.
The appropriate SDWIS/FED bromate MCL violation data elements and individual DTP transactions are
listed below in Exhibit 2.3.
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C 1 1 03 Contaminant Code 1011
C1105 Violation Type Code 02
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be 3 months later than C1107
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
3-11
GA1234572
GA1234572
GA1234572
GA1234572
12-18
0400001
0400001
0400001
0400001
19-25
26
I
I
I
I
27-31
C1103
C1105
C1107
C1109
32-71
1011
02
20040401
20040630
72-74
75-80
Exhibit 2.3 Bromate MCL Violation Data Element Table and DTF Transactions
Example #7 - Calculating Bromate Compliance Based on a Complete Year of Data
Table 2-15 summarizes the bromate monitoring results for 2004. On December 15, 2004 System B's
operator collects the grab samples for bromate at the entrance to the distribution system from both ozone
plant 1 and ozone plant 2. Results are recorded on the bromate monitoring form. Since System B has
completed a full year of bromate monitoring, the operator calculates the RAA for each plant. First, he
calculates the sum of the 12 monthly values, then divides the sum by 12. This calculation is complete for
each plant. The RAA for plant 1 is 0.020 mg/L and for plant 2 is 0.010 mg/L.
Example #7 Decision
System B is in violation of the bromate MCL. The operator must report a violation of the bromate MCL
because of the results for ozone plant 1 (i.e., the RAA exceeds 0.010 mg/L).
January 2003
Page 2 - 32
Stage 1 DBPR Reporting Guidance
-------
Table 2-15. System B 4th Quarter 2004 Bromate Monitoring Results
Month Plant #1 Distribution System Plant #2 Distribution System
Entrance Result (mg/L) Entrance Result (mg/L)
1st Quarter 0.028,0.020,0.027 0.014,0.009,0.007
2ndQuarter 0.018,0.028,0.020 0.006,0.015,0.009
3rd Quarter 0.015,0.029,0.014 0.006,0.014,0.008
4thQuarter 0.014,0.020,0.007 0.012,0.008,0.012
Compliance Sum 0.240 0.120
Calculation
-12 0.020 0.010
4thQuarter 0.020 > 0.010 0.010<0.010
RAA
Public Notice Requirements
System B must provide Tier 2 public notice of the MCL violation according to the requirements of 40
CFR141.201.
System Reporting Requirements
The reporting requirements for bromate are summarized in Table 2-13.
Primacy Agency to SDWIS/FED Reporting
Primacy Agencies report noncompliance for the entire water system If one plant is in violation then the
system is in violation. SDWISReporting Code 02/1011.
The appropriate SDWIS/FED bromate MCL violation data elements and individual DTF transactions are
listed below in Exhibit 2.4.
Stage 1 DBPR Reporting Guidance Page 2 - 33 January 2003
-------
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C 1 1 03 Contaminant Code 1011
C 1 1 05 Violation Type Code 02
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be 3 months later than C1107
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
3-11
GA1234572
GA1234572
GA1234572
GA1234572
12-18
0500001
0500001
0500001
0500001
19-25
26
I
I
I
I
27-31
C1103
C1105
C1107
C1109
32-71
1011
02
20041001
20041231
72-74
75-80
Exhibit 2.4 Bromate MCL Violation Data Element Table and DTF Transactions
Example #8 - Calculating RAA for Bromate
Table 2-16 summarizes the bromate monitoring results for July 2004 to June 2005. On June 15, 2005
System B's operator collects the grab samples for bromate at the entrance to the distribution system from
both ozone plant 1 and ozone plant 2. He records the results on the bromate monitoring form.
For plant 1 the bromate concentration is 0.010 mg/L and for plant 2 the concentration is 0.008 mg/L. The
operator makes operational adjustments to plant 1, requests permission from the Primacy Agency, and
collects additional bromate samples at the entrance to the distribution system from plant 1 on June 17,
2005 (0.005 mg/L), and on June 25, 2005 (0.006 mg/L). Since more than the one compliance sample was
collected from plant 1, the operator must use all of the data when determining compliance. Therefore, he
calculates the average of the 3 samples collected in June 2005 for plant 1.
Since the 2nd calendar quarter is over and System B's operator has completed more than a full year of
bromate monitoring, the bromate RAA must be calculated for each plant, and that value compared to the
bromate MCL.
To calculate an RAA, the operator calculates the sum of the monthly bromate values (or the monthly
average concentration values, if more than one sample per month is taken) for June 2005, May 2005,
April 2005, March 2005, February 2005, January 2005, December 2004, November 2004, October 2004,
September 2004, August 2004 and July 2004 (see Table 2-16). That sum is divided by 12 to create an
arithmetic average of monthly averages. This value is recorded on the bromate monitoring form for each
plant. The RAA for plant 1 is 0.010 mg/L and for plant 2 is 0.009 mg/L.
January 2003
Page 2 - 34
Stage 1 DBPR Reporting Guidance
-------
Table 2-16. System B RAA Bromate Monitoring Results
Month/Quarter
July 2004
August 2004
September 2004
October 2004
November 2004
December 2004
January 2005
February 2005
March 2005
April 2005
May 2005
June 2005 results
Plant #1 Distribution
System Entrance Result
(mg/L)
0.015
0.029
0.014
0.014
0.020
0.007
0.002
0.004
0.002
0.005
0.003
0.010, 0.005,0.006
avg = 0.007
Plant #2 Distribution System Entrance
Result (mg/L)
0.006
0.014
0.008
0.012
0.008
0.012
0.009
0.007
0.010
0.007
0.009
0.008
Compliance
Calculations
Sum
-12
2nd Quarter
0.122
0.01017 = 0.010
0.010 <0. 010
0.110
0.00917 = 0.009
0.009<0.010
RAA
Example #8 Decision
System B is in compliance with the MCL for bromate for the RAA compliance period of July 1, 2004 to
June 30, 2005. Therefore, the Primacy Agency does not report any information to EPA for this time
period.
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System B is in compliance with the Stage 1 DBPR for bromate, the system must routinely
report the information included in Table 2-13 to the Primacy Agency.
Stage 1 DBPR Reporting Guidance
Page 2 - 35
January 2003
-------
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Example #9 - Bromate MCL Exceedance
Assume all of the facts from Example #8, however, assume that the monitoring results for the period July
2004 to June 2005 are as shown below in Table 2-17. Assume that the sum of monthly average bromate
concentrations for plant #1 is 0.096 mg/L, and that the sum of the monthly average bromate
concentrations for plant #2 is 0.130 mg/L. At the end of June 2005, upon calculation of the RAA for
plant 1 the result is 0.008 mg/L bromate and for plant 2 the result is 0.011 mg/L bromate.
Table 2-17. System B June 2005 RAA Bromate Monitoring Results
Month/Quarter
Plant #1 Distribution System
Entrance Result (mg/L)
Plant #2 Distribution System
Entrance Result (mg/L)
Compliance
Calculations
Sum
-12
2nd Quarter
RAA
0.096
0.008
0.008<0.010
0.130
0.0108 = 0.011
0.011 > 0.010
Example #9 Decision
System B must report a violation of the MCL for bromate at the end of June 2005, for the compliance
period of April 1, 2005 to June 30, 2005. The running annual arithmetic average of monthly average
concentrations of bromate exceeds the 0.010 mg/L MCL at plant 2. An MCL violation at one plant
results in violation status for the entire system.
Public Notice Requirements
System B must provide Tier 2 public notice of this MCL violation according to the requirements of 40
CFR141.201.
System Reporting Requirements
The reporting requirements for bromate are summarized in Table 2-13.
Primacy Agency to SDWIS/FED Reporting
The appropriate SDWIS/FED bromate MCL violation data elements and individual DTP transactions are
listed below in Exhibit 2.5. The violation compliance period is to be reported representing the quarter in
which the compliance condition was determined (4/2005-6/2005). SDWIS Reporting Code 02/1011.
January 2003
Page 2 - 36
Stage 1 DBPR Reporting Guidance
-------
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C 1 1 03 Contaminant Code 1011
C 1 1 05 Violation Type Code 02
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be 3 months later than C1107
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
3-11
GA1234572
GA1234572
GA1234572
GA1234572
12-18
0500001
0500001
0500001
0500001
19-25
26
I
I
I
I
27-31
C1103
C1105
C1107
C1109
32-71
1011
02
20050401
20050630
72-74
75-80
Exhibit 2.5 Bromate MCL Violation Data Element Table and DTF Transactions
Example #10 - CWS Fails to Collect Several Required Bromate Samples
Table 2-18 summarizes the bromate monitoring results for 2006. On December 15, 2006 System B's
operator collects the monthly grab samples for bromate at the entrance to the distribution system from
both ozone plant 1 and ozone plant 2. After analysis he records the results on the bromate monitoring
form. At the end of the monitoring quarter System B's operator reviews the preceding twelve months'
data in order to calculate an RAA of monthly bromate concentrations.
Example #10 Decision
Review of the preceding twelve months of data shows that bromate samples were taken in only 8 of the
12 months. The operator must sum the available monthly average values and divide by the actual number
of months in which samples were taken, in this case eight. Compliance with the MCL is determined on
the basis of the available data. It is important to note, that although no MCL violation was defined,
monitoring and reporting violations are present in the 1st, 2nd and 4th quarters of 2006. See Section 2.4.3
for a discussion of bromate M&R violations. Further example #10 discussions only address the Bromate
MCL compliance issues.
Public Notice Requirements
Because the system is in compliance with the Bromate MCL, no public notice is required for this
parameter for this reporting period.
Stage 1 DBPR Reporting Guidance
Page 2 - 37
January 2003
-------
System Reporting Requirements
Although System B is in compliance with the Stage 1 DBPR MCL for bromate, the system must
routinely report the information included in Table 2-13 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance with the Bromate MCL, no SDWIS/FED reporting is required for
this parameter for this reporting period.
Table 2-18. System B 2006 RAA Bromate Monitoring Results
Month
Plant #1 Distribution System
Entrance Result (mg/L)
Plant #2 Distribution System Entrance
Result (mg/L)
January 2006
February 2006
March 2006
April 2006
May 2006
June 2006
July 2006
August 2006
September 2006
October 2006
November 2006
December 2006
Compliance Sum
Calculations
-8
4th Quarter
0.011
0.008
no data
no data
0.009
no data
0.003
0.005
0.012
no data
0.013
0.009
0.070
0.00875 = 0.009
0.009 <0. 010
0.012
0.007
no data
no data
0.009
no data
0.010
0.005
0.018
no data
0.006
0.011
0.078
0.00975 = 0.010
0.010<0.010
RAA
January 2003
Page 2 - 38
Stage 1 DBPR Reporting Guidance
-------
2.1.3 Type 02/2456: HAAS (Five Haloacetic Acids) MCL Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, page 4 & 5
Appendix D - Attachments 1,2,3,4, & 5
Cross-reference to Rule:
40CFR141.133(b)(l)
Table 2-19. HAAS MCL Violation
Violation
Code
Contaminant
Code
Violation Description
02
2456
The running annual arithmetic average, computed quarterly, of quarterly
averages, exceeds the MCL of 0.060 mg/L.
The Primacy Agency will record the begin and end dates of the violation
representing the quarter in which the results of the samples exceed the MCL. If
a water system misses one or more samples during that quarter, then only the
available values are used in the computation.
Example System Description - System C
System C is a large Subpart H community water system serving 58,000 people, that uses a lake as its
source and meets the Subpart H filtration avoidance criteria. The system supplies water treated with
chlorine to meet the disinfection requirements of the Surface Water Treatment Rule. The system utilizes
only one source and one treatment plant. The MCL established in the Stage 1 DBPR for HAAS is 0.060
mg/L and compliance is based upon a running annual arithmetic average computed quarterly of quarterly
averages.
System C Summary
Population Served:
Source #1:
Treatment:
58,000
Surface Water
Successfully avoiding filtration, chlorine
Any Subpart H community or NTNC water system serving 10,000 or more people (large Subpart H
system), and utilizing a chemical disinfectant to treat their water must meet the requirements of Stage 1
DBPR beginning January 1, 2002. The requirements of the Stage 1 DBPR include an MCL for Five
Haloacetic Acids (HAAS), as well as the requirement to monitor for HAAS. Each quarter, System C's
certified operator collects four distribution grab samples and has them analyzed by a certified laboratory
for HAAS.
HAAS samples are taken during times when the disinfection system is operating under normal conditions
and samples are collected at the locations and according to the schedule specified in the provisions of the
monitoring plan, including at least 25% in a location representing maximum residence time. Please see
40 CFR141.132(b) for routine monitoring requirements. Table 2- 20 summarizes System C's monitoring
requirements.
The certified operator records the results on an HAAS monitoring form each quarter and at the end of
each calendar quarter calculates a quarterly average concentration of HAAS. He also calculates an
average HAAS concentration for the previous year (using a running annual arithmetic average of the
Stage 1 DBPR Reporting Guidance
Page 2 - 39
January 2003
-------
quarterly average for the quarter just completed and the average values for the three previous quarterly
monitoring periods). He compares the result to the HAAS MCL of 0.060 mg/L. A violation of the MCL
for HAAS is defined as any running annual arithmetic average computed quarterly - of quarterly
arithmetic averages of all samples collected - that exceeds the 0.060 mg/L MCL established for HAAS.
During the 1st full year of HAAS monitoring, at the end of each calendar quarter, the operator calculates
the sum of the available quarterly averages, assumes zeros for quarters for which monitoring has not yet
occurred, divides the result by four, compares the result to the MCL and records the value on the HAAS
monitoring form. Section 2.1 discusses compliance calculations for the first year of compliance
monitoring in more detail. Please refer to Section 2.4.7 for a discussion of monitoring and reporting
violations for HAAS.
Table 2-20. System C Monitoring Summary
PARAMETER
OR
TASK
Disinfectants:
Chlorine /
Chloramines
DBFs:
TTHM /HAAS
Monitoring Plan
REQUIRED
SAMPLE LOCATION SAMPLE FREQUENCY
Plant Entrance to Distribution Daily Monthly Quarterly Annually
Distribution System or
System less than
annually
| YES NO SUB
X II DAI
X X
X
MIT MONITORING PLAN 1
VI ACY AGEN CY B Y SPEC IF
X
O YES NO
x
1 Same date, location, and time as total coliform samples are collected.
Example #11 - HAAS MCL RAA Calculating After 1st Quarter
Table 2-21 summarizes the HAAS monitoring results for 2002. On February 20, 2002, System C's
operator collects the four required HAAS samples in the distribution system for the 1st quarterly period of
2002. The results are 0.038 mg/L, 0.012 mg/L, 0.060 mg/L and 0.041 mg/L. He calculates an arithmetic
average of the values and records the result on the HAAS monitoring sheet. The arithmetic average for
the 1st quarter of 2002 is 0.038 mg/L.
January 2003
Page 2 - 40
Stage 1 DBPR Reporting Guidance
-------
Table 2-21. System C 1st Quarter 2002 HAAS Monitoring Results
Month/Quarter Results (mg/L)
February 20021 Quarter 1 0.038, 0.012, 0.060, 0.041
Average (0.038 + 0.012 + 0.060 + 0.041) = 0.151 /4 = 0.038
Compliance Sum 0.038
Calculations
-4 0.0095 = 0.010
1st Quarter 0.010 < 0.060
RAA
Example #11 Decision
At the end of March 2002, since System C's operator has not completed one year of HAAS monitoring,
the method of calculating 1st year RAA is used. The 1st quarterly average value of 0.03 8 mg/L is used
and it is assumed, for purposes of the calculation, that the next three quarterly average values are zero.
The 1st year RAA is calculated as shown in Table 2-21. The calculated RAA of 0.010 mg/L is less than
the MCL of 0.060 mg/L set for HAAS. The system is in compliance for the 1st quarter of 2002.
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System C is incompliance with Stage 1 DBPR for HAAS, the system must routinely report the
information summarized in Table 2-22 to the Primacy Agency, according to the requirements of 40
CFR141.134.
Table 2-22. TTHM and HAAS Reporting Requirement [40 CFR 141.134]
For water systems
monitoring for TTHM
and HAAS under the
requirements of
40 CFR141.132(b)
Systems required to sample quarterly or more frequently must report to the Primacy
Agency within 10 days after the end of each quarter in which samples are collected.
The water system must report to the Primacy Agency:
(1) The number of samples taken during the kst quarter
(2) The location, date and result of each sample taken during the last quarter
(3) The arithmetic average of all samples taken in the last quarter
(4) The annual arithmetic average of the quarterly arithmetic averages of this
section for the last four quarters
(5) Whether, based on §141.133(b)(l), the MCL was violated
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Stage 1 DBPR Reporting Guidance Page 2-41 January 2003
-------
Example #12 - HAAS Compliance Calculation During 1st Year of Monitoring
On May 20, 2002, System C's operator collects the four required HAAS samples in the distribution
system for the 2nd quarterly period of 2002. The results are 0.209 mg/L, 0.100 mg/L, 0.168 mg/L and
0.610 mg/L. He calculates an arithmetic average of the values and records the result on the HAAS
monitoring sheet shown in Table 2-23. The arithmetic average is 0272 mg/L.
Table 2-23. System C 2002 HAAS Monitoring Results
Month/Quarter Plant #1 Distribution System Results (mg/L)
Feb 20021 Quarter 1 0.038, 0.012, 0.060, 0.041
1st Quarter Average (0.038 + 0.012 + 0.060 + 0.041) = 0.151 /4 = 0.038
May 2002/Quarter 2 0.209,0.100,0.168,0.610
2nd Quarter Average (0.209 + 0.100 + 0.168 + 0.610) / 4 = 0.272
Compliance Sum (0.038 + 0.272) = 0.310
Calculation
-4 0.0775 = 0.078
2nd Quarter 0.078 > 0.060
RAA
Example #12 Decision
System C is in violation of the HAAS MCL. At the end of June 2002, since system C's operator has not
completed one year of HAAS monitoring, he must use the methodology for calculating the RAA within
the 1st year of monitoring. The 1st quarterly average value is 0.038 mg/L and the 2nd quarterly average
value is 0.272 mg/L. He assumes the next two average results of quarterly monitoring are each equal to
zero, and calculates the RAA = 0.078 mg/L as shown in Table 2- 23. The RAA exceeds the MCL of
0.060 mg/L set for HAAS. A violation of the MCL for HAAS is defined. A violation of the HAAS MCL
at the end of June 2002 must be reported for the compliance period April 1, 2002 to June 30, 2002. The
operator will also need to report MCL violations for HAAS at the end of September 2002, December
2002, and March 2003.
Beginning January 1, 2002, System C must comply with the requirements of the Interim Enhanced
Surface Water Treatment Rule (IESWTR) as well as the requirements of the Stage 1 D/DBP Rule. One
IESWTR requirement is that water systems avoiding filtration must comply with the requirements of the
Stage 1 D/DBP Rule as a condition of their filtration avoidance determination. In Example #12, System
C has violated the HAAS MCL, and is therefore not in compliance with the Stage 1 D/DBP Rule. The
State or Primacy Agency should consider whether System C's filtration avoidance determination should
be revoked because of the HAAS MCL violation.
Public Notice Requirements
System C must provide Tier 2 public notice of this MCL violation according to the requirements of 40
CFR141.201.
January 2003 Page 2 - 42 Stage 1 DBPR Reporting Guidance
-------
System Reporting Requirements
The reporting requirements for HAAS are summarized in Table 2-22.
Primacy Agency to SDWIS/FED Reporting
The appropriate SDWIS/FED HAAS MCL violation data elements are listed below. The Primacy
Agency must also report these violations to EPA after the monitoring for the quarter is completed, even
though the water system's noncompliance is known in advance. Exhibit 2.6 shows the data elements and
individual DTP transactions. SD WIS Reporting Code 02/2456.
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C1103 Contaminant Code 2456
C 1 1 05 Violation Type Code 02
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be 3 months later than C1107
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
3-11
GA1234571
GA1234571
GA1234571
GA1234571
12-18
0200001
0200001
0200001
0200001
19-25
26
I
I
I
I
27-31
C1103
C1105
C1107
C1109
32-71
2456
02
20020401
20020630
72-74
Exhibit 2.6 HAAS MCL Violation Data Element Table and DTF Transactions
Example #13 - HAA5 MCL Full Year RAA Calculation
Table 2-24 summarizes the HAAS monitoring results for 2003. On June 20, 2003, System C's operator
collects the four required HAAS samples in the distribution system for the 2nd quarterly period of 2003.
The results are 0.030 mg/L, 0.015 mg/L, 0.050 mg/L and 0.041 mg/L. He calculates an arithmetic
average of the values and records the result on the HAAS monitoring sheet. The arithmetic average for
the 2nd quarter of 2003 is 0.034 mg/L. The quarterly averages for the previous 3 quarters are: 0.029
mg/L, 0.040 mg/L, and 0.025 mg/L. The RAA for this period is 0.032 mg/L.
Stage 1 DBPR Reporting Guidance
Page 2 - 43
January 2003
-------
Table 2-24. System C 2nd Quarter 2003 HAAS Monitoring Results
Quarter Quarterly Average (mg/L)
Q32002 0.029
Q42002 0.040
Ql 2003 0.025
Q2 2003 (0.030 + 0.015 +0.050 +0.041) / 4 = 0.034
Compliance Sum 0.128
Calculations
-4 0.032
2rd Quarter RAA 0.032 < 0.060
Example #13 Decision
System C is in compliance with the MCL for HAAS at the end of June, 2003. Table 2- 24 presents the
RAA calculations for System C.
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
The reporting requirements for HAAS are summarized in Table 2-22.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Example# 14 - HAAS Missing Samples
Table 2-25 summarizes the monitoring results for HAAS through September 2003. On October 1, 2003,
System C's operator returns from a vacation and finds that no HAAS samples were collected as
scheduled for the 3rd quarter of 2003. Four HAAS grab samples should have been taken in the 3rd quarter.
System C's operator must calculate an RAA at the end of the 3rd quarter using the available data. Since
he does not have sample results for the 3rd quarter, he calculates the sums of the quarterly average HAAS
values for the 2nd and 1st quarters of 2003 and the 4th quarter of 2002. He then divides that sum by 3 to
produce the RAA value to compare to the MCL for determining compliance. The data used in the RAA
calculation is presented in Table 2-25.
January 2003 Page 2 - 44 Stage 1 DBPR Reporting Guidance
-------
Table 2-25. System C 2nd Quarter 2003 HAAS RAA Monitoring Results
Quarter Quarterly Average (mg/L)
4th Quarter 2002 0.040
1st Quarter 2002 0.025
2nd Quarter 2003 0.034
3rd Quarter 2003 No Data
Compliance Sum 0.099
Calculations
-3 0.033
3rd Quarter RAA 0.033 < 0.060
Example #14 Decision
System C is in compliance with the HAAS MCL at the end of the 3rd quarter of 2003. However, the
system must report an M&R violation for failing to collect and analyze its HAAS samples for the 3rd
quarter of 2003. Please see Section 2.4.7 for a discussion of HAAS M&R violations. All further
discussions on Example #14 only address the MCL compliance issues.
Public Notice Requirements
Because the system is in compliance with the HAAS MCL , no public notice is required for this
parameter for this reporting period.
System Reporting Requirements
Although System C is incompliance with the MCL for HAAS, the operator must routinely report the
information presented in Table 2-22 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance with the HAAS MCL, no SDWIS/FED reporting is required for this
parameter for this reporting period.
Stage 1 DBPR Reporting Guidance Page 2 - 45 January 2003
-------
2.1.4 Type 02/2950: TTHM (Total Trihalomethanes) MCL Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, page 4 & 5
Appendix D, Attachments 1,2,3,4 & 5
Cross-reference to Rule:
40CFR141.133(b)(l)
Table 2-26. TTHM MC L Violation
Violation Contaminant Violation Description
Code Code
02
2950
The runn ing annual arithm etic average , compute d quarterly,
averages, exceeds the MCL of 0.080 mg/L
o f quarterly
Example System Description - System D
System D is a small Subpart H system serving 8,200 people that uses 3 large groundwater wells
determined to be under the direct influence of surface water. The system treats the water from each well
by filtration through cartridge and bag filters and by disinfection with chlorine gas on a full-time basis.
The system utilizes three filtration/disinfection treatment plants known as TP 1, TP 2 and TP 3.
System D Summary
Population Served: 8,200
Source #1: Well 1
Treatment: Filtration, chlorine
Source #2: Well 2
Treatment: Filtration, chlorine
Source #3: Well 3
Treatment: Filtration, chlorine
Any Subpart H community or NTNC water system serving less than 10,000 people (small Subpart H
system), and utilizing a chemical disinfectant to treat water must meet the requirements of Stage 1 DBPR
beginning January 1, 2004. The requirements of the Stage 1 DBPR include an MCL for Total
Trihalomethanes (TTHM), as well as the requirement to monitor for TTHM. System D's certified
operator collects and has a certified laboratory analyze one grab sample per plant for TTHM during the
1st month of each quarter in a location within the distribution system from each plant that represents
maximum residence time.
In an effort to enhance operational control and better protect public health, the operator also collects and
analyzes one grab sample per plant at the points of maximum residence time during the 2nd and 3rd
months of each quarter. This sample frequency is described in the system monitoring plan submitted to
the Primacy Agency. A summary of System D's monitoring requirements is presented in Table 2-27. He
takes the TTHM samples during times when the disinfection systems are operating under normal
conditions and he collects the samples at the locations (i.e. points of maximum residence time ) and
according to the schedule specified in the provisions of the monitoring plan. He records the results of the
samples on a TTHM monitoring form each month and at the end of each calendar quarter he calculates a
quarterly average concentration of TTHM for the system All existing sample data must be used in this
January 2003 Page 2 - 46 Stage 1 DBPR Reporting Guidance
-------
calculation, even though he has sampled more frequently than required for a system of System D's size.
He also calculates an average TTHM concentration for the system for the previous year (a running
annual arithmetic average of the quarterly average for the quarter just completed and the average values
for the three previous quarterly monitoring periods) and compares the result to the TTHM MCL of 0.080
mg/L.
Table 2-27. System D Monitoring Summary
PARAMETER
OR TASK
Disinfectants
SAMPLE LOCATION
Plant Entrance to Distribution
Distribution System
System
SAMPLE FREQUENCY
Daily
Monthly Quarterly
Annually or
less than
annually
Chlorine
DBPs
X
X
TTHM /HAA5
X
X1
Monitoring Plan
REQUIRED
^•|| YES NO
•rar
SUBMIT MONITORING PLAN
TO PRIMACY AGENCY BY
SPECIFIC DATE
YES
NO
X
1 System is required to collect one sample per plant per quarter. However, additional monitoring is performed for
process control as outlined in the monitoring plan
A violation of the MCL for TTHM is defined as any running annual arithmetic average, computed
quarterly, of quarterly arithmetic averages of all samples collected, that exceeds the 0.080 mg/L MCL
established for TTHM. Additionally, during the 1st full year of TTHM monitoring, at the end of each
calendar quarter, the operator calculates the sum of the available quarterly averages and records the value
on the TTHM monitoring form. During the 1st full year of TTHM monitoring, a violation of the MCL
for TTHM is defined for the system when the sum of the available quarterly (average) TTHM
concentrations plus assumed zeros for quarters for which monitoring has not yet been performed, divided
by four, will yield a result greater than the MCL of 0.080 mg/L set for TTHM. Please refer to Section
2.4.7 for a discussion of monitoring and reporting for TTHM.
Example #15 - TTHM MCL 1st Quarter of Data
Table 2-28 summarizes the TTHM monitoring results for the 1st quarter of 2004. In March 2004, System
D's operator collects the 3rd scheduled set of 3 TTHM samples (one per plant at point of maximum
residence time) for the 1st quarter, has the samples analyzed by a certified laboratory, and enters the
values on the TTHM monitoring form. Since he has collected a total of (3) three distribution system
samples per plant (nine samples) during the quarter, he calculates an arithmetic average value for TTHM
for the system and enters it on the TTHM monitoring form. The average of all samples taken at the
points of maximum residence time during the quarter is 0.063 mg/L (0.0627 rounded to 0.063 mg/L).
Stage 1 DBPR Reporting Guidance
Page 2 - 47
January 2003
-------
Table 2-28. System D 1st Quarter 2004 TTHM Monitoring Results
Month/Quarter Average of Sampling Points 1, 2, and 3 (mg/L)
January 2004/Q1 0.061
February2004/Ql 0.063
March 2004/Q1 0.065
Quarterly Average (mg/L) 0.063
Compliance Sum 0.063
Calculation
-4 0.01575 = 0.016
1st Quarter RAA 0.016 < 0.080
Example #15 Decision
Since system D's operator has not completed a full year of TTHM monitoring, he must use the 1st year
RAA calculation methodology for calculating a running annual (arithmetic) average. He calculates the
sum of the 1st quarter average value in the distribution system (0.063 mg/L) and the assumed zeros for the
other three quarters, and divides the total by 4. Since the RAA is not greater than 0.080 mg/L, System D
is in compliance with the MCL for TTHM after the 1st quarter of 2004.
Public Reporting Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System D is in compliance with the TTHM MCL, the operator must routinely report the
information presented in Table 2-22 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Example #16 - TTHM MCL 3rd Quarter RAA
Table 2-29 summarizes the TTHM monitoring results for 2004. In September 2004, System D's operator
collects the 3rd scheduled set of 3 TTHM samples (one per plant at the point of maximum residence time)
for the 3rd quarter of monitoring in 2004. He enters the values on the TTHM monitoring forms. Since he
has collected three sets of 3 samples during the 3rd quarter, he calculates a quarterly arithmetic average
concentration for the system and records that value on the TTHM monitoring forms. The quarterly
average of all TTHM samples collected for the 3rd quarter is 0.140 mg/L. Assume the 2nd quarter's
average is 0.125 mg/L.
January 2003 Page 2 - 48 Stage 1 DBPR Reporting Guidance
-------
Table 2-29. System D 2004 TTHM Monitoring Results
Quarter Average of Sampling Points 1, 2, and 3 (mg/L)
Ql 0.063
Q2 0.125
Q3 0.140
Compliance Calculation Sum 0.328
-4 0.082
3rd Quarter RAA 0.082 > 0.080
Example #16 Decision
Since System D's operator has not completed one full year of monitoring for TTHM, he cannot calculate
a running annual arithmetic average and must use the 1st year RAA calculation methodology. He sums
the three available quarterly arithmetic average values and assumes zero for the remaining quarter and
divides the result by four to determine compliance with the MCL of 0.080 mg/L. The result is 0.082
mg/L. He must report an MCL violation since the sum of available quarterly average values divided by 4
is greater than the MCL of 0.080 mg/L. System D has already exceeded the TTHM MCL in the third
quarter, when it was assumed that the fourth quarter value was 0 mg/L. Therefore, the system will also
be out of compliance in the fourth quarter of 2004.
Public Notice Requirements
System D must provide Tier 2 public notice of this MCL violation according to the requirements of 40
CFR141.201.
System Reporting Requirements
System D's operator must notify the Primacy Agency regarding the MCL violation according to the
requirements of 40 CFR141.134, as summarized in Table 2-22.
Primacy Agency to SDWIS/FED Reporting
The appropriate SDWIS/FED TTHM MCL violation data elements and individual DTP transactions are
listed below in Exhibit 2.7. The violation begin and end dates should be reported as the quarter in which
the noncompliance condition was determined (July 2004 - Sept. 2004). SDWIS Reporting Code
02/2950.
Stage 1 DBPR Reporting Guidance Page 2 - 49 January 2003
-------
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C1103 Contaminant Code 2950
C 1 1 05 Violation Type Code 02
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be 3 months later than C1107
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
3-11
GA1234570
GA1234570
GA1234570
GA1234570
12-18
0400001
0400001
0400001
0400001
19-25
26
I
I
I
I
27-31
C1103
C1105
C1107
C1109
32-71
2950
02
20040701
20040930
72-74
75-80
Exhibit 2.7 TTHM MCL Violation Data Element Table and DTF Transactions
2.2 MRDL Violations
General Discussion of Maximum Residual Disinfectant Level (MRDL) Violations
The Stage 1 DBPR established MRDLs for three chemical disinfectants - chlorine, chlorarrines and
chlorine dioxide. Disinfectants are used to control risks from microbial pathogens, but represent a
subsequent health risk if present in the finished water at excessive levels. The MRDL violations are
similar to MCL violations.
Table 2-30. Regulated Disinfectant MRDLs
Regulated Disinfectants
Chlorine
Chloramines
Chlorine Dioxide
Maximum Residual Disinfectant Levels
(mg/L)
4.0 as C12
4.0 as C12
0.8
Chlorine and chloramine MRDL compliance is based on a running annual arithmetic average, computed
quarterly, of the monthly average of all samples. Chlorine and chloramine residuals are measured at the
same location and frequency in the distribution system as are total coliform samples required for
compliance with the Total Coliform Rule.
January 2003
Page 2 - 50
Stage 1 DBPR Reporting Guidance
-------
All MRDL violations for chlorine and chloramines are considered to be non-acute. Therefore, the
violation type code of 11 should be used for these violations.
For chlorine and chloramines, the beginning and ending dates of the violation should be reported as the
quarter in which the monthly samples create an RAA exceeding the MRDL. No analytic result is
required as part of the SDWIS report of a violation. Table 2-31 presents a summary of the MRDL
Violation reporting codes.
In cases where a system switches between the use of chlorine and chloramines for residual disinfection
during the year, compliance must be determined by including together all monitoring results of both
chlorine and chloramines in calculating compliance. Reports submitted by the system must clearly
indicate which residual disinfectant was analyzed for each sample.
Chlorine dioxide is monitored daily at the entrance to the distribution system. When any daily sample
exceeds the MRDL, the system must take a 3-sample set from the distribution system the next day in
addition to the daily entry point sample. A violation of the chlorine dioxide MRDL is defined by ANY
one of the following conditions:
• Any one of the 3 distribution system samples taken in response to an entry point MRDL
exceedance which also exceeds the MRDL; or
• Any two consecutive daily entry point samples exceed the MRDL (regardless of distribution
system monitoring results); or
• The water system fails to perform distribution system monitoring following an entry point
exceedance; or
• The water system fails to perform entry point monitoring following an entry point exceedance.
When reporting chlorine dioxide violations the compliance period should be reported for periods of 1
month. Both Compliance Period Begin Date and Compliance Period End Date must be supplied. A new
numeric field, Cl 112, has been supplied in which to record the number of times the chlorine dioxide
MRDL was exceeded during the month. The violation type code (Cl 105) will distinguish between an
acute and nonacute chlorine dioxide MRDL violation (code 11= nonacute, code 13 = acute).
Chlorine dioxide MRDL violations maybe either acute or nonacute violations. An acute violation occurs
if a daily entry point sample exceeds the MRDL and any of the 3 distribution samples collected the
following day exceed the MRDL, or there is a failure to take distribution system samples following an
entry point exceedance. A nonacute violation occurs if two consecutive entry point samples exceed the
MRDL but none of the 3-sample set distribution samples exceed the MRDL, or the water system fails to
take an entry point sample on the day following an entry point MRDL exceedance.
Stage 1 DBPR Reporting Guidance Page 2-51 January 2003
-------
Table 2-31. SDWIS/FED Codes for MRDL Reporting Under the Stage 1 DBPR
Violation
Code
11
13
Contaminant
Code
0999
1006
1008
1008
MRDL Violations
Chlorine MRDL - Nonacute
Chloramines MRDL - Nonacute
Chlorine D ioxide - No nacute
Chlorine Dioxide -Acute
2.2.1 Type 11/0999: Chlorine MRDL Violation
Cross-reference to Stage 1 DBPR Implementation Guidance:
Section II, pages 4 and 6
Appendix D, Attachments 1, 2, 3, 4, & 5
Cross-reference to Rule:
40CFR141.133(c)(l)
Table 2-32. Chlorine MRDL Violation
Violation
Code
11
Contaminant
Code
0999
Violation Description
The running annual arithmetic average, computed quarterly, of monthly
averages of all samples collected exceeds the MRDL of 4.0 mg/L (unless the
increased residual levels in the distribution system are necessary to address
specific microbiological contamination problems)
Example System Description - System E
System E is a small Subpart H system serving 1,800 people that uses surface water from a small river.
The system treats the water with a direct filtration plant and uses chlorine as a primary and secondary
disinfectant. The system utilizes one source and one treatment plant. Finished water from the plant
enters the distribution system at site 1.
System E Summary
Population Served:
Source #1:
Treatment:
1,800
River
direct filtration, chlorine
Any Subpart H community or NTNC water system, serving less than 10,000 people (small Subpart H
system) and adding a chemical disinfectant to treat water must meet the requirements of Stage 1 DBPR
beginning January 1, 2004. The requirements of the Stage 1 DBPR include an MRDL for chlorine, as
well as the requirement to monitor for chlorine. System E's certified operator collects and analyzes grab
samples for either total or free chlorine from the same locations and on the same frequency as the total
coliform bacteria samples during each month of each quarter. System E's certified operator continues to
take chlorine samples during times when the disinfection system is operating under normal conditions,
and when the chlorine residual is increased in response to specific microbiological contamination
January 2003
Page 2 - 52
Stage 1 DBPR Reporting Guidance
-------
problems. Higher chlorine residual measurements taken while a specific microbiological problem is
being addressed are included in MRDL RAA compliance calculations.
Samples are collected at the locations and according to the schedule specified in the monitoring
requirements summarized in Table 2-33.
Table 2-33. System E Monitoring Summary
PARAMETER
OR
TASK
Disinfectants:
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distributio
n
System
Distribution
System
Daily Monthly Quarterly
Annually
or
less than
annually
Chlorine
DBPs:
X
X
TTHM /HAA5
X
Monitoring Plan
EQUIRED
YES NO
X
SUBMIT MONITORING PLAN
TO PRIMACY AGENCY BY
SPECIFIC DATE
YES
NO
X
(<3,300
people
served)
The certified operator records the results on a chlorine monitoring form each day that coliform samples
are collected. At the end of each calendar month an average chlorine concentration is calculated for the
month. At the end of each calendar quarter, he calculates an average of all monthly averages (an annual
average of the previous 12 monthly averages), and compares the result to the chlorine MRDL of 4.0
mg/L. A violation of the MRDL for chlorine is defined as any running annual arithmetic average,
computed quarterly, of monthly arithmetic averages that exceeds the 4.0 mg/L MRDL established for
chlorine. Additionally, during the 1st full year of chlorine monitoring, at the end of each calendar quarter,
System E's operator calculates the sum of the available monthly averages, and records the value on the
chlorine monitoring form. During the 1st full year of chlorine monitoring, a violation of the MRDL for
chlorine is defined when the sum of the available monthly averages of chlorine concentrations plus
assumed zeros for samples not yet taken, divided by 12, exceeds 4.0 mg/L. Otherwise, an evaluation for
system compliance with the MRDL for chlorine, using a running annual arithmetic average calculation, is
1st accomplished 12 months after the effective date of the rule. Please refer to Section 2.4.2 for a
discussion of chlorine monitoring and reporting requirements and associated violations.
Example #17 - Chlorine MRDL 1st Quarter RAA
Table 2-34 summarizes the chlorine monitoring results for the 1st quarter of 2004. System E's operator
collects two samples per month at the same locations as total coliform bacteria samples. On March 20,
2004, System E's operator collects and analyzes the sixth and last chlorine residual sample in the
distribution system for the 1st quarter of 2004. He calculates a monthly arithmetic average of the chlorine
residual values and records it on the chlorine residual monitoring form. The averages for the months of
Stage 1 DBPR Reporting Guidance
Page 2 - 53
January 2003
-------
January (2.9 mg/L), February (4.1 mg/L) and March (3.5 mg/L) of 2004 are all less than or very close to
the 4.0 mg/L.
Table 2-34. System E 1st Quarter 2004 Chlorine Residual Monitoring Results
Date of Sample
January 2004
February 2004
March 2004
Compliance
Calculations
Sum
-12
Monthly Average Result (mg/L)
2.9
4.1
3.5
10.5
0.875 = 0.88
1st Quarter 0.88 < 4.0
RAA
Example #17 Decision
Since System E's operator has not completed one full year of monitoring for chlorine residual, an RAA
chlorine concentration cannot be calculated. He calculates the sum of the monthly averages for January,
February, and March, assumes zeros for months for which monitoring has not yet occurred, and divides
the result by 12 in order to determine compliance. Because the result is not greater than the 4.0 mg/L
MCL, the operator is not required to report a chlorine MRDL violation after the 1st quarter of 2004. At
the end of March 2004, this system is in compliance with the requirements of the Stage 1 DBPR
regarding the MRDL for chlorine.
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System E is in compliance with the MCL for chlorine, the operator must routinely report the
information summarized in Table 2-35 below to the Primacy Agency.
Table 2-35. Chlorine or Chloramines Reporting Requirement [40 CFR 141.134]
Water systems
monitoring for
chlorine or
chloramines under the
requirements of
40 CFR141.132(c)
Systems required to sample quarterly or more frequently must report to the Primacy
Agency within 10 days after the end of each quarter in which samples are collected.
Water Systems must report to the Primacy Agency:
(1) The number of samples taken during each month of the last quarter
(2) The monthly arithmetic average of all samples taken in each month for the
last 12 months
(3) The arithmetic average of the monthly averages for the last 12 months
(4) Whether, based on §141.133(c)(l) the MRDL was violated
Primacy Agency to SDWIS/FED Reporting
January 2003
Page 2 - 54
Stage 1 DBPR Reporting Guidance
-------
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Example #18 - Chlorine MRDL 3rd Quarter
Table 2-36 summarizes the chlorine monitoring results for 2004. On September 20, 2004, System E's
operator collects and analyzes the sixth 3rd quarter chlorine residual sample from the distribution system.
The operator records the value on the chlorine residual monitoring form and calculates the September
monthly arithmetic average and records that value on the monitoring form. Since the 3rd quarter 2004
monitoring is complete, the operator calculates the monthly arithmetic average of all samples taken
during the 3rd quarter, and records those values ( 5.1 mg/L, 4.7, mg/L and 4.9 mg/L) on the monitoring
form. The monthly average values have been ranging above the MRDL of 4.0 mg/L, so the operator
suspects the system maybe in violation of the chlorine MRDL.
Table 2-36. System E 3rd Quarter 2004 Chlorine Residual Monitoring Results
Date of Sample Monthly Average Result (mg/L)
January 2004 2.9
February 2004 4.1
March 2004 3.5
April 2004 5.2
May 2004 5.1
June 2004 4.4
July 2004 5.1
August 2004 4.7
September 2004 4.9
Compliance Sum 39.9
Calculations
-12 3.3
3rd Quarter RAA 3.3 < 4.0
Example #18 Decision
Since System E's operator has not completed one full year of monitoring for chlorine residual an RAA
chlorine concentration cannot be calculated. He calculates the sum of the 1st nine monthly arithmetic
average concentrations, assumes zeros for the three remaining months of the year and divides that sum by
12 in order to determine compliance. The result of 3.3 mg/L is less than the MRDL of 4.0 mg/L.
Therefore, the system remains in compliance with the MRDL for chlorine after the 3rd quarter of 2004.
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
Stage 1 DBPR Reporting Guidance Page 2 - 55 January 2003
-------
System Reporting Requirements
Although System E is in compliance with the chlorine MRDL, System E must routinely report the
information presented in Table 2-35 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Example #19 - Chlorine MRDL Full Year RAA
Table 2-37 summarizes the chlorine residual monitoring results for 2004. On December 20, 2004,
System E's operator collects and analyzes the sixth quarterly chlorine residual sample and records the
result on the system chlorine monitoring form. He calculates a monthly arithmetic average chlorine
value for December and records it on the system monitoring form. The monthly averages for the 4th
quarter of 2004 are: October(4.1 mg/L), November (3.3 mg/L) and December (2.9 mg/L).
Table 2-37. System E 4th Quarter 2004 Chlorine Residual Results
Date of Sample Monthly Average Result (mg/L)
January 2004/Q1 2.9
February 2004/Q1 4.1
March 2004/Q1 3.5
April2004/Q2 5.2
May2004/Q2 5.1
June 2004/Q2 4.4
July2004/Q3 5.1
August2004/Q3 4.7
September 2004/Q3 4.9
October 2004/Q4 4.1
November 2004/Q4 3.3
December 2004/Q4 2.9
Compliance Sum 50.2
Calculations
-12 4.183 = 4.2
4th Quarter RAA 4.2 > 4.0
Example #19 Decision
Since System E's operator has completed one year of monitoring, he must determine compliance based
upon a running annual arithmetic average of monthly arithmetic average chlorine concentrations recorded
during the previous 12 months. He calculates the average of the monthly averages of the previous 12
months and finds the result is 4.2 mg/L. He compares this value to the MRDL of 4.0 mg/L, and it is
January 2003 Page 2 - 56 Stage 1 DBPR Reporting Guidance
-------
greater than the MRDL. The system is in violation of the Stage 1 DBPR requirements for chlorine after
the 4th quarter of 2004, because the running annual arithmetic average of monthly arithmetic average
chlorine concentrations is greater than the MRDL.
Public Notice Requirements
System E must provide Tier 2 public notice of this MRDL violation according to the requirements of 40
CFR 141.201.
System Reporting Requirements
System E must routinely report the information presented in Table 2-35 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
The Appropriate SDWIS/FED chlorine MRDL violation data elements are listed below. Exhibit 2.8
Shows the data elements and individual DTP transactions. SDWISReporting Code 11/0999.
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C1103 Contaminant Code 0999
C 1 1 05 Violation Type Code 11
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be 3 months later than C1107
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
3-11
GA1234572
GA1234572
GA1234572
GA1234572
12-18
0500001
0500001
0500001
0500001
19-25
26
I
I
I
I
27-31
C1103
C1105
C1107
C1109
32-71
0999
11
20041001
20041231
72-74
75-80
Exhibit 2.8 Chlorine MRDL Violation Data Element Table and DTF Transactions
2.2.2 Type 11/1006: Chloramines MRDL Violation
Cross-reference to Stage 1 DBPR Implementation Guidance:
Section II, pages 4 and 6
Appendix D, Attachments 1, 2, 3, 4, & 5
Cross-reference to Rule:
40CFR141.133(c)(l)
Stage 1 DBPR Reporting Guidance
Page 2 - 57
January 2003
-------
Table 2-38. Chloramines MRDL Violation
Violation
Code
11
Contaminant
Code
1006
Violation Description
The runn ing annual arithm etic average , compute d quarterly, o f monthly
averages of all samples collected, exceeds the MRDL of 4.0 mg/L (unless
increased residual levels in the distribution system are necessary to address
specific microbiological contamination problems).
Example System Description - System F
System F is a large Subpart H system serving 22,000 people. The system has a microfiltration membrane
plant and disinfects the water with chloramines.
System F Summary
Population Served: 22,000
S ource # 1: high mountain la ke
Treatment: membrane filtration, chloramines
Any Subpart H community or NTNC water system serving more than 10,000 people (large Subpart H
system), and adding a chemical disinfectant to treat water must meet the requirements of Stage 1 DBPR
after January 1, 2002. The requirements of the Stage 1 DBPR include a MRDL for chloramines, as well
as the requirement to monitor for chloramines. System F's certified operator collects and analyzes one
grab sample for either combined or total chlorine from the same locations and on the same frequency as
the total coliform bacteria samples. For this size system, the minimum number of samples allowed under
the Total Coliform Rule is 25 per month, however, System F's written monitoring plan describes 36
samples per month. System F's certified operator continues to take chlorine samples during times when
the disinfection system is op crating under normal conditions and when the chlorine residual is increased
in response to specific microbiological contamination problems. Higher chlorine concentrations
measured while a specific microbiological problem is being addressed are included in the MRDL RAA
compliance calculations.
Samples are collected at the locations and according to the system monitoring requirements summarized
in Table 2-39. Chloramine monitoring results are reported as either total or combined chlorine, in mg/L.
The operator records the results on a chloramine monitoring form each day that measurements are made,
and at the end of each calendar month he calculates an average chloramine concentration by summing the
individual results and dividing bythe number of samples (36 in this case). The results are expressed as
mg/L of chlorine. At the end of each calendar quarter, System F's operator calculates an average of
monthly averages of chlorine concentrations for all samples collected and compares the result to the
chloramine MRDL of 4.0 mg/L (as chlorine).
A violation of the MRDL for chloramine is defined as any running annual arithmetic average, computed
quarterly, of monthly arithmetic averages of all samples collected, that exceeds the 4.0 mg/L (as chlorine)
MRDL established for chloramines. During the 1st full year of monitoring the operator must use the 1st
year RAA calculation methodology. At the end of each calendar quarter, the operator calculates the sum
of the available monthly averages, assumes zero for the months not yet monitored, and divides the sum
by 12. A violation of the MRDL for chloramines is defined when the sum of the available monthly
(average) chlorine concentrations and assumed zero concentrations for the remainder of the year, divided
January 2003 Page 2 - 58 Stage 1 DBPR Reporting Guidance
-------
by 12, exceeds the MRDL of 4.0 mg/L. See Section 2 for a description of the calculation of an RAA
during the first year of monitoring.
Table 2-39. System F Monitoring Summary
PARAMETER
OR
TASK
Disinfectants:
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distributio
n
System
Distribution
System
Daily Monthly Quarterly
Annually
or
less than
annually
Chloramines
DBPs:
X
X
TTHM /HAA5
X
I Monitoring Plan
REQUIRED
YES
NO
SUBMIT MONITORING PLAN
TO PRIMACY AGENCY BY
SPECIFIC DATE
YES
NO
X
Please refer to Section 2.4.4 for a discussion of monitoring and reporting violations for chloramines.
Example #20 - Chloramines MRDL Full Year RAA in Compliance
Table 2-40 summarizes the chloramine monitoring results for 2002. On December 31st, 2002, System F's
certified operator collects and analyzes the last of the December 2002 chloramine samples from the
distribution system. A monthly arithmetic average chloramine concentration is calculated for the month
of December 2002 using all 36 samples and that value is recorded on the monitoring form. Since the
operator has completed the 4th quarter of 2002, he calculates an average of all monthly averages of the
year 2002. Since the operator has completed one full year of chloramine monitoring, he must determine
compliance with the MRDL for chloramines by calculating a running annual arithmetic average of the
monthly arithmetic average concentrations for the previous 12 months.
Stage 1 DBPR Reporting Guidance
Page 2 - 59
January 2003
-------
Table 2-40. System F 2002 Chloramine Monitoring Results
Date of Sample
January 2002
February 2002
March 2002
April 2002
May 2002
June 2002
July 2002
August 2002
September 2002
October 2002
November 2002
December 2002
Compliance Sum
Calculations
- 12
4thQuar
Monthly Average Results (mg/L)
3.8
4.2
3.3
2.9
3.7
3.6
3.9
3.5
3.3
3.7
3.4
3.3
42.6
3.55 = 3.6
•ter RAA 3. 6 < 4.0
Example #20 Decision
Since System F's operator has completed a full year of chloramine monitoring, he compares the running
annual arithmetic average of monthly averages for the previous 12 month period (3.6 mg/L) to the MRDL
established for chloramines (4.0 mg/L as chlorine). System F is incompliance with the MRDL for
chloramines at the end of December 2002.
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System F is in compliance with the MRDL for chloramines, it must routinely report the
information presented in Table 2-35 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
January 2003
Page 2 - 60
Stage 1 DBPR Reporting Guidance
-------
Example #21 - Chloramines MRDL Full Year RAA in Violation
Table 2-41 summarizes the SystemF chloramine monitoring results. On June 30, 2003, System F's
certified operator collects and analyzes the last of the 36 monthly chloramine samples from the
distribution system for June 2003 according to the system's monitoring plan. A monthly arithmetic
average chloramine concentration expressed as mg/L of chlorine is calculated for the month of June 2003
and is recorded on the monitoring form. Since System F has completed more than one full year of
chloramine monitoring, he must determine compliance with the MRDL for chloramines by calculating a
running annual arithmetic average of the monthly arithmetic average concentrations for the previous 12
months. The running annual arithmetic average concentration is 4.1 mg/L (as chlorine).
Table 2-41. System F Chloramine Monitoring RAA Results
Date of Sample
July 2002
August 2002
September 2002
October 2002
November 2002
December 2002
January 2003
February 2003
March 2003
April 2003
May 2003
June 2003
Compliance
Calculations
Example #21 Decision
Sum
-12
2nd Quarter RAA
Monthly average Results (mg/L)
3.9
3.5
3.3
3.7
3.4
3.3
4.4
4.6
4.8
4.9
4.7
4.7
49.2
4.1
4.1 > 4.0
Since System F has completed more than a full year of chloramine monitoring, the operator compares the
running annual arithmetic average for the previous 12 month period (4.1 mg/L) to the MRDL established
for chloramines (4.0 mg/L). The operator must report an MRDL violation for chloramines at the end of
June 2003.
Public Notice Requirements
System F must provide Tier 2 public notice of the MRDL violation according to the requirements of 40
CFR141.201.
Stage 1 DBPR Reporting Guidance
Page 2-61
January 2003
-------
System Reporting Requirements
System F's operator must notify the Primacy Agency regarding the MRDL violation as summarized in
Table 2-35.
Primacy Agency to SDWIS/FED Reporting
The appropriate SDWIS/FED chloramines MRDL violation data elements and individual DTP
transactions are listed below in Exhibit 2.9. SD WIS Reporting Code 11/1006.
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C 1 1 03 Contaminant Code 1006
C 1 1 05 Violation Type Code 11
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be 3 months later than C1107
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
3-11
GA1234575
GA1234575
GA1234575
GA1234575
12-18
0300001
0300001
0300001
0300001
19-25
26
I
I
I
I
27-31
C1103
C1105
C1107
C1109
32-71
1006
11
20030401
20030630
72-74
75-80
Exhibit 2.9 Chloramine MRDL Violation Data Element Table and DTF
Transactions
January 2003
Page 2 - 62
Stage 1 DBPR Reporting Guidance
-------
2.2.3 Type 11/1008: Chlorine Dioxide MRDL Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, pages 4 and 6
Appendix D, Attachment 6
Cross-reference to Rule:
40CFR141.133(c)(2)
Table 2-42. Chlorine Dioxide MRDL Violations
Violation
Code
Contaminant
Code
Violation Description
13
1008
Acute Violation: When any daily sample taken at the entrance to the
distribution system exceeds the MRDL of 0.8 mg/L, AND, on the following
day one or more of the three samples taken in the distribution system also
exceeds the MRDL of 0.8 mg/L; failure to take distribution system samples
following an entry point exceedance.
11
1008
Non-Acute Violation: When any daily sample taken at entrance to the
distribution system exceeds the MRDL of 0.8 mg/L, AND, on the following
day, the daily sample taken at the entrance to the d istribution system also
exceeds the MRDL of 0.8 mg/L and all distribution system samples are less
than or equal to the MRDL of 0.8 mg/L; failure to take entry point sample the
day following an entry point exceedance.
General Discussion of Chlorine Dioxide Violations
SDWIS/FED has established Cl 112 as a new data element number in which to record the number of
times the MRDL was exceeded during the reporting month. When reporting to SDWIS the violation type
code is used to distinguish between acute and non-acute violations. Systems may incur and must report
to SDWIS/FED both acute and non-acute violations during the same reporting month.
Example System Description - System AA
System AA is a large Subpart H system serving 49,000 people that uses surface water. The system has a
conventional treatment plant and treats the surface water with chlorine dioxide for taste and odor control.
Chlorine is added as a primary and secondary disinfectant. System AA has a booster chlorination facility
in a remote location within the distribution system in order to maintain an adequate chlorine residual.
System AA Summary
Population Served: 49,000
Source #1: Surface water
Treatment: Conventional filtration, chlorine dioxide, chlorine
The MRDL established for chlorine dioxide in the Stage 1 DBPR is 0.8 mg/L. Compliance is based upon
the results of samples taken on consecutive days. In addition, the rule specifies that an MRDL violation
has occurred when a system fails to take the additional distribution system samples required on the day
following a routine daily entrance sample analysis result that exceeds 0.8 mg/L chlorine dioxide, or the
Stage 1 DBPR Reporting Guidance
Page 2 - 63
January 2003
-------
routine entrance to the distribution system sample on any day following a routine daily entrance sample
analysis result that exceeds 0.8mg/L chlorine dioxide.
Any SubpartH community or NTNC water system serving more than 10,000 people (large Subpart H
system), and utilizing chlorine dioxide as a disinfectant or oxidant to treat water must meet the
requirements of Stage 1 DBPR beginning January 1, 2002. The requirements of the Stage 1 DBPR
include an MRDL for chlorine dioxide, as well as the requirement to monitor daily for chlorine dioxide.
System AA's certified operator collects and analyzes one grab sample daily for chlorine dioxide at the
entrance to the distribution system. The routine sample is collected each day at the location and
according to the monitoring requirements summarized in Table 2-43.
Table 2-43. System AA Chlorine Dioxide Monitoring Summary
PARAMETER
OR TASK
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distributio
n
System
Distribution
System
Daily Monthly Quarterly
Annually or
less than
annually
Disinfectants:
Chlorine
Chlorine Dioxide
X
X
X
X
X
An additional distribution system 3- sample set must be
collected the day folowing any exceedanceof 0.8 mg/L
at the entran ce to the distri bution system
DBPs:
TTHM /HAA5
Chlorite (Daily) (grab)
(3-sample set)
(3-sample set)
X
X
X
X
X
X
X
A distribution system 3-sample set must be collected on
the day following any daily sample that exceeds 1 .0
mg/L at the entran ce to the distri bution system
DBP Precursors:
Paired TOC
Alkalinity
(asCaCO3)
SUVA*
Monitoring Plan
REQUIRED
X
X
X
^^^^^^^^^^^—
YES
NO SU
1U
X SP
X
X
X
EMIT MONITORING PLAN
> PRIMACY AGENCY BY
ECIFIC DATE
YES NO
I x 1
Optional - Alternative compliance criteria requirement of40 CFR 141.135
January 2003
Page 2 - 64
Stage 1 DBPR Reporting Guidance
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The results are recorded on a chlorine dioxide monitoring form each day, and compared to the MRDL of
0.8 mg/L. On the day following any daily routine sample result that exceeds the 0.8 mg/L MRDL, in
addition to the daily routine sample, the operator must collect and analyze three chlorine dioxide samples
in the distribution system. Since System AA operates a chlorine residual booster station, the operator
takes three samples at the following locations: one as close as possible to the 1st customer, one in a
location representative of average residence time, and one as close to the end of the distribution system
as possible (representing maximum residence time). The results of this monitoring are recorded on the
chlorine dioxide monitoring form and each result compared to the chlorine dioxide MRDL of 0.8 mg/L.
An acute violation of the chlorine dioxide MRDL is defined when any daily routine sample at the
entrance to the distribution system exceeds the MRDL of 0.8 mg/L, and, on the following day one or
more of the three additional samples taken in the distribution system exceeds the MRDL of 0.8 mg/L, or
when the system fails to collect and analyze the distribution system samples the day following an entry
point exceedance of the MRDL values.
A non-acute violation of the chlorine dioxide MRDL is defined when any two consecutive routine daily
samples taken at the entrance to the distribution system exceed the MRDL of 0.8 mg/L, while all of the
additional samples taken in the distribution system are less than the MRDL of 0.8 mg/L, or when the
system fails to collect and analyze the daily sample at the entrance to the distribution system the day
following and entry point exceedance. Please refer to Section 2.4.6 for a discussion of monitoring and
reporting for chlorine dioxide.
Example #22 - Chlorine Dioxide MRDL Acute and Non-Acute Violation
Table 2-44 summarizes the January 2002 data for system AA.
On January 1,2002 and on January 2, 2002, System AA's operator collects and analyzes the routine daily
chlorine dioxide samples from the entrance to the distribution system. The results are both 0.7 mg/L. On
January 3, 2002, the operator collects and analyzes the routine daily chlorine dioxide sample from the
entrance to the distribution system. The result is 1.0 mg/L. This value, which is > 0.8 mg/L, triggers a
requirement for additional distribution system samples on the following day. On January 4, 2002, he
collects the routine daily entrance to the distribution system sample and then collects the three additional
distribution system samples according to the monitoring plan. The routine sample on January 4, 2002 is
0.9 mg/L and the three additional samples are 0.9 mg/L, 0.8 mg/L and 0.5 mg/L. On January 5, 2002, he
collects and analyzes the routine daily sample for chlorine dioxide at the entrance to the distribution
system, and the three additional samples. The routine sample is 0.9 mg/L and the additional samples are
0.8 mg/L, 0.7 mg/L, and 0.5 mg/L. On January 6, 2002, he collects and analyzes the routine daily sample
for chlorine dioxide at the entrance to the distribution system, and the three additional samples. The
routine sample is 0.7 mg/L and the additional samples are 0.7 mg/L, 0.7 mg/L, and 0.5 mg/L. On January
7 through 28, System AA's operator collects and analyzes a routine, daily sample for chlorine dioxide,
and on each day the result is less than the MRDL of 0.8 mg/L. On January 29, 2002, he collects and
analyzes the routine daily sample for chlorine dioxide at the entrance to the distribution system. The
result is 0.9 mg/L. On January 30, 2002, he collects and analyzes the routine daily sample for chlorine
dioxide at the entrance to the distribution system, and the three additional samples. The routine sample is
0.8 mg/L and the additional samples are 0.8 mg/L, 0.7 mg/L and 0.6 mg/L. On January 31, 2002, the
operator collects and analyzes the routine daily sample for chlorine dioxide at the entrance to the
distribution system. The result is 0.7 mg/L.
Stage 1 DBPR Reporting Guidance Page 2 - 65 January 2003
-------
Table 2-44. System AA January 2002 Chlorine Dioxide Monitoring Results
(mg/L)
Sunday
Monday
Tuesday
Day 1
0.7 mg/L
Wednesday Thursday
Friday
Saturday
Day 2
0.7 mg/L
Day 3
1.0 mg/L
Day 4 Day 5
0.9 mg/L 0.9 mg/L
Day 6
0.7 mg/L
0.7 mg/L
0.7 mg/L
0.5 mg/L
Day 13
0.5 mg/L
Day 20
0.3 mg/L
Day 27
0.6 mg/L
Day 7
0.7 mg/L
Day 14
0.7 mg/L
Day 21
0.4 mg/L
Day 28
0.8 mg/L
Day 8
0.6 mg/L
Day 15
0.6 mg/L
Day 22
0.7 mg/L
Day 29
0.9 mg/L
Day 9
0.4 mg/L
Day 16
0.6 mg/L
Day 23
0.7 mg/L
Day 30
0.8 mg/L
0.8 mg/L
0.7 mg/L
0.6 mg/L
0.9 mg/L 0.8 mg/L
0.8 mg/L 0.7 mg/L
0.5 mg/L 0.5 mg/L
Day 10
0.8 mg/L
Day 17
0.6 mg/L
Day 24
0.7 mg/L
Day 31
0.7 mg/L
Day 11
0.8 mg/L
Day 18
0.7 mg/L
Day 25
0.8 mg/L
Day 12
0.7 mg/L
Day 19
0.7 mg/L
Day 26
0.7 mg/L
Note: the values to the top left of each day's square are dailyroutine monitoring entranceto the distribution system
results and the values to the right of the day square are additional monitoring in the distribution system, required the
day following a day when any daily entranceto the distribution system routine sample exceeds the 0.8 mg/L MRDL
for chlorine dioxide.
Example #22 Decision
System AA incurs one acute violation of the MRDL and one non-acute violation of the MRDL for
January 2002. Since compliance with the chlorine dioxide MRDL is based upon consecutive daily
samples, System AA's operator must review each day's chlorine dioxide monitoring results in
conjunction with the results from the previous day. Additionally, after comparing each day's entrance to
the distribution system monitoring results to the MRDL for chlorine dioxide, the operator must determine
the need for appropriate additional distribution system monitoring required when the MRDL is exceeded
in any daily entrance to the distribution system sample.
Compliance with the MRDL is determined against a definition of both an acute and a non-acute
violation. System AA must report an acute violation of the MRDL for chlorine dioxide for January 4th,
because the MRDL of 0.8 mg/L was exceeded at the entrance to the distribution system January 3, 2002
and in the additional distribution system samples (0.9 mg/L) collected on January 4, 2002. For January
5th, the operator must report a 2nd MRDL violation. However, it is defined as a non-acute violation,
because only the entry point samples exceeded the MRDL on two consecutive days (January 4th and
January 5th). Later in the month, on January 29, 2002, System AA's operator collects and analyzes a
routine daily sample that exceeds the MRDL (0.9 mg/L). However, a violation is not defined for this
date because neither the January 30, 2002 routine sample or the three additional distribution system
samples for January 30, 2002 exceed the MRDL of 0.8 mg/L.
January 2003
Page 2 - 66
Stage 1 DBPR Reporting Guidance
-------
Public Notice Requirements
System AA must provide Tier 1 public notice of the acute MRDL violations incurred on January 4th,
according to the requirements of 40 CFR141.201. The non-acute MRDL violation incurred on January
5th requires Tier 2 public notice.
System Reporting Requirements
System AA's operator must summarize the appropriate information for the 1st quarter of 2002 and report
to the Primacy Agency within 10 days of the end of the quarter. System AA must routinely report the
information in Table 2-45 to the Primacy Agency.
Table 2-45. Chlorine Dioxide Reporting Requirement [40 CFR 141.134]
Water systems
monitoring for
chlorine dioxide
under the
requirements of
40 CFR141.132(c)
Systems required to sample quarterly or more frequently must report to the Primacy
Agency within 10 days after the end of each quarter in which samples are collected.
Water systems must report to the Primacy Agency:
(1) The dates, results and locations of samples taken during the last quarter
(2) Whether, based on §141.133(c)(2) the MRDL was violated
(3) Whether, the MRDL was exceeded in any two consecutive daily samples and
whether the resulting violation was acute or non-acute.
Primacy Agency to SDWIS/FED Reporting
At the end of the 1st quarter of monitoring, the operatorwill report that during the month of January 2002,
the MRDL for chlorine dioxide was violated two times in two sets of consecutive daily samples. One
instance was an acute violation, SDWISReporting Code 13/1008, while the other instance defined a
non-acute violation of the MRDL. SDWIS Reporting Code 11/1008
The appropriate SDWIS/FED chlorine dioxide MRDL violation data elements and individual DTP
transactions for an acute and a non-acute violation are listed below in Exhibit 2.10.
Stage 1 DBPR Reporting Guidance Page 2 - 67 January 2003
-------
Data Elements:
Number Name Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
Cl 1 03 Contaminant Code 1 008
C 1 1 05 Violation Type Code 13
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be one month later than C1107
C1112 Severity Indicator Count Number of violations
DTP Transactions: Acute Violation
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234576
GA1234576
GA1234576
GA1234576
GA1234576
12-18
0200001
0200001
0200001
0200001
0200001
19-25
DTP Transactions: Non-acute Violation
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234576
GA1234576
GA1234576
GA1234576
GA1234576
12-18
0200002
0200002
0200002
0200002
0200002
19-25
26
I
I
I
I
I
26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1112
27-31
C1103
C1105
C1107
C1109
C1112
32-71
1008
13
20020101
20020131
1
32-71
1008
11
20020101
20020131
1
72-74
72-74
75-80
75-80
Exhibit 2.10 Chlorine Dioxide Acute and Non-Acute MRDL Violation Data
Element Table and DTF Transactions
January 2003
Page 2 - 68
Stage 1 DBPR Reporting Guidance
-------
2.3 Treatment Technique Violations
Treatment Technique violations are caused by a failure to meet TT performance requirements. Table 2-
46 presents a summary of all Treatment Technique violation reporting codes for the Stage 1 DBPR.
Table 2-46. SDWIS/FED Codes for TT Reporting Under the Stage 1 DBPR
Violation Contaminant Treatment Technique Violations
Code Code
12
37
46
0400
0400
2920
Failure to have qualified operator in charge after effective date of the rule
Failure to submit/obtain Primacy Agency approval for significant treatment
modifications
Failure to meet DBF precursor removal (TOC)
2.3.1 Type 12/0400: Qualified Operator in Charge
Cross-reference to Stage 1 DBPR Implementation Guidance:
Section II, page 4 & 8
Section IV-D, page 37
Cross-reference to Rule:
40CFR141.130(c)
Table 2-47.
Violation Contaminant
Code Code
12
0400
Failure
plant.
Qualified
Operator
TT Violation
Violation Description
to have a
State-approved and
listed qualified operator running
the
Example System Description - System BB
System BB is a large Subpart H system serving 12,000 people that uses surface water that has a direct
filtration plant. Chlorine is used as a primary and secondary disinfectant. The system has only one
source and one plant.
System BB Summary
Population Served: 12,000
Source: Surface water
Treatment: Direct filtration, chlorine
Any Subpart H community or NTNCWS serving 10,000 or more people (large Subpart H system), and
utilizing chlorine as a disinfectant or oxidantto treat water must meet the requirements of Stage 1 DBPR
beginning January 1, 2002. Requirements of the Stage 1 DBPR include a Treatment Technique
requirement that the system be operated under the control of a qualified operator who is included in a
Primacy Agency register of qualified operators.
Stage 1 DBPR Reporting Guidance Page 2 - 69 January 2003
-------
Example #23 - Qualified Operator (TT)
On July 1, 2002, System BB's qualified operator terminates his employment, and System BB
immediately hires another person to operate the water treatment plant. On the date of the employment,
the new person is not a certified operator, and therefore is not included on the Primacy Agency register of
qualified operators. On September 30,2002, during a sanitary survey, the surveyor becomes aware that
the operator is not a qualified operator. The surveyor immediately notifies the Primacy Agency.
Example #23 Decision
Since System BB's new operator is not a certified operator at the end of the 3rd quarter of 2002, and since
he is not included on a Primacy Agency register of qualified operators, System BB is in violation of the
Stage 1 DBPR.
Public Notice Requirements
System BB must provide, at the discretion and direction of the Primacy Agency, public notice of the TT
violation according to the requirements of 40 CFR141.201.
System Reporting Requirements
There are no specific system reporting requirements for this violation.
Primacy Agency to SDWIS/FED Reporting
System BB is considered out of compliance from July 1, 2002 until the date on which a qualified
operator is in charge of the treatment system. Since this date may not be known at the time the Primacy
Agency submits the violation to EPA, the SDWIS/FED data system will default the compliance period
end date to December 31, 2015. When the water system meets the requirements of havinga certified
operator in charge of the facility, the Primacy Agency should submit a "return to compliance"
enforcement action entry to SDWIS/FED and link it to the violation. The enforcement action return to
compliance date shall be either the date the Primacy Agency becomes aware of the certified operator, or
the date on which the certified operator became in charge of system operations. When this enforcement
action is posted to the database and linked to the violation, this returned to compliance date replaces the
SDWIS/FED default violation end date. SD WIS Reporting Code 12/0400.
The appropriate SDWIS/FED TT violation data elements and individual DTP transactions are presented
in Exhibit 2-11.
January 2003 Page 2 - 70 Stage 1 DBPR Reporting Guidance
-------
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C1103 Contaminant Code 0400
C 1 1 05 Violation Type Code 12
Cl 107 Compliance Period Begin Date
C1109 Compliance Period End Date SDWIS/FED will default to 20151231
DTP Transactions:
1-2
Dl
Dl
Dl
3-11
GA1234578
GA1234578
GA1234578
12-18 19-25 26
0200001 I
0200001 I
0200001 I
27-31 32-71 72-74 75-80
C1103 0400
C1105 12
C1107 20020701
Exhibit 2.11 Qualified Operator TT Violation Data Element Table and DTF
Transactions
2.3.2 Type 37/0400: Unapproved Treatment Modifications TT Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, page 4 & 8
Cross-reference to Rule:
40 CFR141.30(f) (Sunsets with effective date of Stage 1 rule)
General Discussion of Treatment Modifications TT Violations
The TT criteria of the Total Trihalomethane Rule applicable to Subpart H CWSs that add a chemical
disinfectant to the water in any part of the drinking water treatment process, require that prior to
implementation of treatment modifications each system must submit a plan detailing such modifications
to the Primacy Agency for review and approval (40 CFR 141.3 0(f)). These requirements also apply until
January 1, 2004 to ground water systems serving a population of 10,000 or more.
Community water systems using only ground water, serving 10,000 or more people and adding a
chemical disinfectant or oxidant to treat water are not required to meet the Stage 1 DBPR until January 1,
2004. However, these systems mustmeet the requirements of 40 CFR141.30 (a) - (g) until that date
pursuant to 40 CFR141.30(h). The 1979 TTHM Rule was amended to include a treatment technique
requirement that, prior to implementation of significant treatment process modifications to comply with
the MCL for TTHM, each system must submit a plan detailing the modifications to the Primacy Agency
for review and approval prior to implementation (40 CFR141.30(f)). Therefore, a system's certified
operator must prepare a treatment system modification plan (STPM), including the elements outlined in
40 CFR141.30 (f)(l) through (f)(5), submit it to the Primacy Agency, and the system must receive
Stage 1 DBPR Reporting Guidance
Page 2-71
January 2003
-------
approval of the plan from the Primacy Agency, all prior to implementing the treatment plant
modifications. These requirements are intended to ensure that microbial protection continues in a water
system during the time the system is making any treatment process changes necessary to comply with the
new requirements of the Stage 1 DBPR.
Example System Description - System CC
System CC is a ground water system serving 19,300 people. The ground water sources are treated only
by addition of chlorine. All wells are connected by a manifold and treated with a single chlorination
plant.
System CC Summary
Population Served: 19,300
Source: Groundwater
Treatment: Chlorine
Example #24 - Significant Treatment Process Modification Plan (TT)
On September 10, 2002, System CC submits a plan to the Primacy Agency detailing modifications to its
disinfection process intended to improve control of their delivery of disinfectant, and to allow more
precise measurement of residual disinfectant. The plan contains all the elements described in 40
CFR141.30 (f). On September 20, 2002, without receiving approval of the plan from the Primacy
Agency, contractors for System CC begin construction necessary to implement the plan.
Example #24 Decision
Although System CC appropriately prepared the necessary significant treatment plant modification plan,
it has committed a TT violation as a result of the system's initiation of construction of significant
treatment process modifications without receiving approval from the Primacy Agency. The compliance
period begin date is either the date the unapproved construction began (if known) or the date the Primacy
Agency learns that the unapproved construction has begun. The compliance period end date is the date
on which the Primacy Agency notifies the system that the modification plan is approved. If the date of
modification plan approval is unknown at the end of a reporting period, then the compliance period end
date will be defaulted to December 31,2015 (20151231) by SDWLS/FED. When the Primacy Agency
approves the plan it should report that actual compliance period and date to SDWLS/FED by using a link
to a "return to compliance" enforcement action.
Public Notice Requirements
System CC must provide, at the discretion and direction of the Primacy Agency, public notice of this TT
violation according to the requirements of 40 CFR141.201.
System Reporting Requirements
There are no specific system reporting requirements for this violation.
January 2003 Page 2 - 72 Stage 1 DBPR Reporting Guidance
-------
Primacy Agency to SDWIS/FED Reporting
Stage 1 DBPR Reporting Guidance Page 2 - 73 January 2003
-------
The appropriate SDWIS/FED Treatment Technique violation data elements and individual DTP
transactions for a failure to receive approval of a STPM plan prior to initiation of construction are listed
below in Exhibit 2.12. SDWIS Reporting Code 37/0400
Data Elements:
Number Name
C0101 PWS-ID
CHOI Violation ID
C 1 1 03 Contaminant Code
Value or Comment
Qualifier 1
Qualifier 2
0400
C1105 Violation Type Code 37
C1107 Compliance Period Begin Date Actual or date Primacy Agency aware
C 1 1 09 Compliance Period End Date SD WIS/FED will default to December 31,
2015
DTP Transactions:
1-
D
D
D
2 3-11
1 GA1234578
1 GA1234578
1 GA1234578
12-18 19-25 26
0200001 I
0200001 I
0200001 I
27-31 32-71 72-74 75-80
C1103 0400
C1105 37
C1107 20020920
Exhibit 2.12 Significant Treatment Plant Modification TT Violation Data Element
Table and DTF Transactions
2.3.3 Type 46/2920: DBF Precursors Removal TT Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, pages 4 and 8
Section IV-D, page 28
Appendix D, Attachment 8
Cross-reference to Rule:
40CFR141.133(d)
Table 2-48. DBPP Removal Treatment Technique Violation
Violation
Code
46
Contaminant
Code
2920
Violation Description
A failure to meet the Treatment Technique requirements for DBF
Removals. (Compliance determined quarterly)
Precursor
Example System Description - System DP
January 2003
Page 2 - 74
Stage 1 DBPR Reporting Guidance
-------
System DD is a large Subpart H system serving 109,000 people that uses surface water. It uses a
conventional filtration treatment plant as defined in 40 CFR141.2, including softening. The system
supplies water treated with chlorine on a routine basis. The system utilizes the single source and plant 1.
System DD Summary
Population Served:
Source #1:
Treatment #1:
109,000
Surface water
Conventional filtration, chlorine, softening
Any Subpart H community water system, serving 10,000 or more people (large Subpart H system), and
utilizing a chemical disinfectant or oxidant to treat water must meet the requirements of Stage 1 DBPR
beginning January 1, 2002. The requirements of the Stage 1 DBPR include a Treatment Technique (TT)
requirement for control of disinfection byproduct precursors (DBPP). The TT requirements are
applicable to Subpart H CWSs & NTNCWSsthat use conventional filtration. The TT requires that each
treatment plant monitor for TOC in the source water and the treated water (paired TOC samples) and for
alkalinity in the source water. Table 249 presents a summary of system DD's monitoring requirements.
Table 2-49. System DD's Monitoring Summary
PARAMETER
OR TASK
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant Entrance to Distribution Daily Monthly Quarterly Annually or
Distribution System less than
System annually
Disinfectants:
Chlorine / Chloramines
DBPs:
| TTHM /HAA5
DBP Precursors:
Paired TOC
Alkalinity (as CaCO3)
Treated Water Alkalinity*
SUVA*
Magnesium Hardness*
(as CaCO3)
ssssr
X
X (raw)
X
X
Xraw
&treated
| YES [ N0 1 SUB
mlO J
SPE
X
X
X
X
X
X
X
X
X
MIT MONITORING PLAN
PRIMACY AGENCY BY
CIFIC DATE
YES NO
X
Optional -Alternative compliance criteria of40 CFR141.135
Stage 1 DBPR Reporting Guidance
Page 2 - 75
January 2003
-------
Subpart H (systems using surface water or GWUDI sources) water systems that use conventional
treatment are required under the Stage 1 DBPR to remove a percentage of the natural organic material
(referred to as total organic carbon or "TOC") from the raw water. TOC is a precursor to DBF. TOC
and the disinfectants used in drinking water treatment can combine to form disinfection byproducts
(DBFs). The necessary TOC removal percentage (called Step 1 compliance) is based upon raw water (or
source water) TOC and alkalinity concentrations (see 40 CFR141.135). A pairof TOC samples must be
taken simultaneously in the raw (source) water and no later than the combined filter effluent (treated
water) at least once per month to allow calculation of system percent TOC removal and to demonstrate
compliance with an RAA. If any TOC data are missing, the RAA is calculated using the available data.
Alternative compliance criteria are also provided to demonstrate compliance using a system's source
water or treated water TOC expressed as RAA, TTHM and HAAS RAA levels, a system's source (raw)
and finished (treated) water SUVA levels, or the results of bench or pilot-scale testing.
TOC percent removal is calculated by dividing the concentration of TOC inmg/L in the treated water by
the TOC concentration in the raw water. Next, subtract that value from 1 and multiply the result by 100.
Finally, compliance with this TT requirement is determined by dividing the actual TOC percent removal
by the required TOC percent removal found in the table in 40 CFR141.135(b)(2). When this value is less
than 1.00, the system is not incompliance with the TOC percent removal requirements.
System DD's certified operator begins collecting and analyzing paired TOC and alkalinity data on
January 1, 2001 (12 months before the January 1, 2002 effective date of the rule) on a monthly frequency
at the plant. This monitoring is suggested to demonstrate compliance with the treatment process TOC
percent removal stated in the Step 1 TOC Removal Requirement as shown in Table 2-50. If a system
fails to meet the Step 1 TOC removal requirements, the system must apply to the Primacy Agency for
retroactive approval of alternative minimum TOC (Step 2) removal requirements, described in
40CRF141.135(a)(2) or (a)(3). If the system elects not to complete this monitoring during the 12 months
prior to the effective date of the rule, then the system cannot be granted retroactive approval of Step 2
during 2002.
Table 2-50. Step 1 Required Removal of TOC by Enhanced Coagulation and
Enhanced Softening for Subpart H Systems Using Conventional Treatment
Source-water TOC
(mg/L)
> 2. 0-4.0
> 4.0 - 8.0
>8.0
Source-water alkalinity, mg/L asCaCO3
0-60
35.0 %
45.0 %
50.0 %
>60 -120
25.0%
35.0%
40.0 %
>120
15.0%
25.0 %
30.0 %
Example #25 - TT (DBPP Reduction) System Meets Alternative Compliance Criteria
Table 2-51 summarizes the source and treated water TOC monitoring results for 2001. On the 15th of
each month, starting with January 15, 2001 and through December 15, 2001, System DD's certified
operator collects and a State-approved laboratory analyzes paired samples for TOC, and a source water
alkalinity sample, and records the results on a DBPP monitoring form. Monthly samples are collected
according to the system monitoring plan and at times representative of normal operating conditions and
normal influent water quality. Each month, the treatment process TOC percent removal is calculated.
January 2003
Page 2 - 76
Stage 1 DBPR Reporting Guidance
-------
System DD's paired TOC monitoring data for 2001 (the 12 months previous to the effective date of the
rule) are displayed in Table 2-51 below.
Table 2-51. System DD 2001 Source and Treated Water TOC Monitoring Results
Source Water (mg/L)
JAN
1.3
RAA =
FEE
1.4
MAR
1.5
APR
1.6
MAY
2.1
JUN
2.2
JUL
2.4
AUG
1.3
SEPT
1.9
(1.3 + 1.4 + 1.5 + 1 .6 + 2.1 + 2.2 +2.4 + 1.3 + 1 .9 + 1.9 + 1.7 + 1.5)/i:
OCT
1.9
NOV
1.7
DEC
1.5
AVG.
RAA
1.7
1 = 1.1
Treated Water (mg/L)
1.2
RAA =
1.2
1.3
1.6
1.9
2.0
2.2
1.3
1.8
(1.2 + 1.2 + 1.3 + 1 .6 + 1.9 + 2.0 + 2.2 + 1.3 + 1 .8 + 1.9 + 1.6 + 1.4)/1
1.9
1.6
1.4
RAA
1.6
2 = 1.6
RAA = Running Annual Arithmetic Average of monthly averages
Example #25 Decision
Since the source water TOC concentration for the 12 months prior to the effective date of the rule is less
than 2.0 mg/L calculated as an RAA of monthly values, System DD believes it will be in compliance
with the TT requirement for DBPP (the alternative compliance criteria found in 40 CFR141.135
(a)(2)(i)). System DD must continue to comply with the monitoring requirements found in 40
CFR141.132(d) (monthlypaired TOC andsource water alkalinity samples).
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System DD is in compliance with the Stage 1 DBPR for TOC, the system must routinely report
the information included in Table 2-53 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Example #26 - TT (DBPP Reduction) Failure to Meet Alternative Compliance Criteria
Table 2-52 summarizes source and treated water TOC monitoring results for 2002. On the 15th of
December 2002, System DD's operator collects and has a State-approved laboratory analyze the
December 2002 monthly paired TOC samples, and the source water alkalinity sample, taken at the same
time, and she records the results on the DBPP monitoring form. Since the 1st year following the effective
date of the rule is completed, and since the 4th quarter of 2002 is completed, the running annual
arithmetic average of monthly average values for source water TOC and treated water TOC is calculated.
Stage 1 DBPR Reporting Guidance
Page 2 - 77
January 2003
-------
Monthly TOC removal percentages are calculated and the calculated removal for each month is divided
by the required percent removal dictated by the rule in 40 CFR141.135 (b)(2). The results are recorded
on the DBPP monitoring form If this value is less than 1.00, system DD is not in compliance with the
TOC percent removal requirement.
Table 2-52. System DD 2002 Source and Treated Water TOC Monitoring Results
Source Water TOC (mg/L)
JAN
1.1
FEE
1.4
MAR
1.4
APR
1.8
MAY
5.0
JUN
7.1
JUL
7.0
AUG
5.2
SEPT
4.8
OCT
3.0
NOV
1.8
DEC
1.1
AVG.
RAA
3.4
Treated Water TOC (mg/L)
1.1
1.2
1.3
1.6
3.0
4.0
4.0
3.0
2.8
2.2
1.6
1.0
RAA
2.2
Source Water Alkalinity (mg/L)
98.0
95.0
85.0
80.0
88.0
90.0
93.0
94.0
95.0
100.0
98.0
91.0
92.2
Calculated TOC Percent Removal (1 - (treated water TOC / source water TOC)) x 100
0
14
7
11
40
44
43
42
42
27
11
9
~
Required TOC Percent Removal (see Table 2-50)
NA
NA
NA
NA
35
35
35
35
35
25
NA
NA
~
Ratio: Calculated TOC / Required TOC
NA
NA
NA
NA
1.1
1.3
1.2
1.2
1.2
1.1
NA
NA
~
RAA = Running Annual Arithmetic Average
NA = Not Applicable, because the system opted for an alternate comp liance criterion for that month.
Example #26 Decision
Since neither the source water TOC average concentration nor the treated water TOC average
concentration for the first 12 months after the effective date of the rule (January 1, 2002) is less than 2.0
mg/L calculated as a running annual arithmetic average, System DD is not in compliance with the
alternative compliance criterion found in 40 CFR141.135 (a)(2)(i) or (ii). Although the first year (2002)
data may meet the alternative compliance criteria in 40 CFR141.135()(2)(iii), since the source water
TOC level is an RAA less than 4.0 mg/L and the source water alkalinity RAA is greater than 60 mg/L (as
CaCO3), for the purposes of this example, please assume that the data is not available to comply with any
of the alternative compliance criteria in 40 CFR141.135(a)(2)(iv through vi). System DD must determine
compliance based upon the minimum Step 1 percent removals specified in 40 CFR141.135(b)(2). Based
upon the data above (the Ratio of Calculated TOC Removal to Required TOC Removal) System DD is
complying with the minimum Step 1 percent removals specified in 40 CFR141.135(b)(2) since that ratio
is greater than 1.0 in each month calculated (May 2002 through October 2002)
Public Notice Requirement
January 2003
Page 2 - 78
Stage 1 DBPR Reporting Guidance
-------
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
System DD must routinely report the following information in Table 2-53 to the Primacy Agency.
Table 2-53. System DD DBPR Removal (TT) Reporting Requirements
[40 CFR 141.134]
Water systems
monitoring monthly or
quarterly for TOC
under the
requirements of 40
CFR141.132 (d) and
required to meet the
enhanced coagulation
or enhanced softening
requirements in
141.135(b)(2) or (3).
Systems required to sample quarterly or more frequently must report to the Primacy
Agency within 10 days after the end of each quarter in which samples are collected.
Water systems must report to the Primacy Agency:
(1) The number of paired samples taken during the last quarter
(2) The location, date and result of each paired sample and associated alkalinity
taken during the last quarter.
(3) For each month in the reporting period that paired samples were taken, the
arithmetic average of the percent reduction of TOC for each paired sample
and the required TOC percent removal.
(4) Calculations for determining compliance with the TOC percent removal
requirements, as provided in 141.135(c)(l).
(5) Whether the system is in compliance with the enhanced coagulation or
enhanced softening percent removal requirements in 141.135(b) for the last
four quarters.
Water systems
monitoring monthly or
quarterly for TOC
under the
requirements of 40
CFR141.132 (d) and
meeting one or more
of the alternative
complian ce criteria in
40 CFR 141.135(a)(2)
or (3).
Systems required to sample quarterly or more frequently must report to the Primacy
Agency within 10 days after the end of each quarter in which samples are collected.
Water systems must report to the Primacy Agency:
(1) The alternative compliance criterion that the system is using
(2) The number of paired samples taken during the last quarter
(3) The location, date and result of each paired sample and associated alkalinity
taken during the last quarter
(4) The RAA based on monthly averages (or quarterly samples) of source water
TOC for systems meeting a criterion in 40 CFR 141.13 5(a)(2)(i) or (iii) or of
treated water TOC for systems meeting the criterion in 40
CFR141.135(a)(2)(ii)
(5) The RAA based on monthly averages (or quarterly samples) of source water
SUVA for systems meeting the criterion in 40 CFR141.135(a)(2)(v) or of
treated water SUVA for systems meeting the criterion in 40
CFR141.135(a)(2)(vi)
(6) The RAA of source water alkalinity for systems meeting the criterion in 40
CFR141.135 (a)(2)(iii) and of treated water alkalinity for systems meeting the
criterion in 40 CFR1 41.135 (a)(3)(i)
(7) The RAA for both TTHM and HAAS for systems meeting the criterion in 40
CFR141.135(a)(2)(iii)or(iv)
(8) The RAA of the amount of magnesium hardness removal (as CaCO3, in
mg/L)for systems meeting the criterion in 40 CFR1 41.135 (a)(3)(ii)
(9) Whether the system is in compliance with the particular alternative
compliance criterion in 40 CFR141.135(a)(2) or(3)
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Stage 1 DBPR Reporting Guidance
Page 2 - 79
January 2003
-------
2.4 Monitoring & Reporting Violations
M&R violations are reported for water systems failing to prepare monitoring plans, submit monitoring
plans as required, monitor the required parameters for the required number of samples, or report the
results of monitoring for the require d number of samples. Table 2-54 presents a summary of all M&R
violation reporting codes.
Table 2-54. SDWIS/FED Codes for Federal Reporting Under the Stage 1 DBPR
Violation
Code
271
Contaminant
Code
0400
1011
2920
approp riate
MCL/MRDL
contaminant
code
Monitoring and Reporting Violations
Major: Failure to develop, implement, or submit monitoring plan
Major: Failure to collect and report 100% of required bromate samples
Major: Failure to collect source and finished water TOC/alkalinity samples
Major: Failure to collect and report at least 90% of required samples
(except for bromate)
Minor: Collecting and reporting between 90-99% of required samples
(except for bromate)
1A SDWIS field is used to distinguish between major or minor for M&R violations where appropriate
2.4.1 Type 27/0400: Monitoring Plan Development and Submittal M&R Violation
General Comments Regarding SDWIS/FED Reporting
When reporting to SDWIS/FED, the compliance period begin date to be reported for PWSs that incur this
type of violation depends upon which monitoring plan provision was violated. For PWS's that fail to
develop and implement the plan, the compliance period begin date should be either January 31, 2002 for
large Subpart H systems (serving at least 10,000 people) or January 31, 2004 for smaller Subpart H
systems (serving fewer than 10,000 people) and all ground water systems.
When water systems have developed and implemented the monitoring plan, but failed to submit the
monitoring plan to the Primacy Agency by the time the first report is due to the Primacy Agency, the
compliance period date will be April 10,2002 for Subpart H systems serving at least 10,000 people, or
April 10, 2004 for subpart H systems serving between 3,301 and 9,999 people.
A water system is considered out of compliance until the Primacy Agency is satisfied that the PWS has
met the requirements of these provisions. Since the date when the PWS regains compliance may not be
known at the time the Primacy Agency must report to SDWIS/FED, the SDWIS/FED data system has
been designed to default the compliance period date of the violation to a date in the future (December 31,
2015). When the water system regains compliance with these requirements, the Primacy agency must
submit a "returned to compliance" enforcement action, and link it to the original violation. The
enforcement action date shall be when the Primacy Agency is satisfied with the PWS monitoring plan or
when the Primacy Agency receives the monitoring plan. When this enforcement action is posted to the
SDWIS/FED database and linked to the violation, the actual date of compliance replaces the default
compliance period end date supplied with the original report to SDWIS/FED.
January 2003
Page 2 - 80
Stage 1 DBPR Reporting Guidance
-------
2.4.1.1 Failure to Develop Monitoring Plan within 30 days of Compliance Date M&R Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, pages 4 and 9
Section IV-D, page 34
Cross-reference to Rule:
40CFR141.132(a)(3)&(f)
Table 2-55. Monitoring Plan Monitoring and Reporting
Violation
Code
27
Contaminant
Code
0400
Violation
Violation Description
A failure to develop a monitoring plan within 30 days
compliance date.
of the initial rule
Example System Description - System EE
System EE is a small community water system serving 3,000 people that uses only ground water
determined not to be under the influence of surface water. The system supplies water treated with
chlorine on a routine basis. The system utilizes one disinfection plant from which water enters the
distribution system.
System EE Summary
Population Served: 3,000
Source: Groundwater (not under the influence)
Treatment: Chlorine
Any community water system serving less than 10,000 people and utilizing a chemical disinfectant or
oxidant to treat water must meet the requirements of Stage 1 DBPR beginning January 1, 2004.
Provisions of the Stage 1 DBPR require systems to prepare a monitoring plan. System EE's certified
operator must prepare a plan including at least the elements contained in 40 CFR141.132(f). She must
prepare the plan within 30 days of the effective date of the rule for the system as described in 40
CFR141.130(b). Accordingto 40 CFR141.130(b)(l) the effective date of the rule for System EE is
January 1, 2004. The monitoring plan must be completed by January 31, 2004.
Example #27 - M&R Monitoring Plan Compliance by System
On December 31, 2003, System EE's operator completes the monitoring plan and includes all of the
elements described in 40 CFR141.132(f). Table 2- 56 summarizes System EE's monitoring
requirements.
Stage 1 DBPR Reporting Guidance Page 2 - 81 January 2003
-------
Table 2-56. System EE Monitoring Summary
PARAMETER
OR
TASK
Disinfectants:
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distributio
n
System
Distribution
System
Daily
Monthly Quarterly
Annually
or
less than
annually
Chlorine /
Chloramines
DBPs:
X
X
TTHM /HAA5 ||
Monitoring Plan
REQUIRED
X
X1
YES NO SUBMIT MONITORING PLAN TO
T»T"»
X
SP
IMACY AGENCY BY
ECIFIC DATE
YES
NO
X
(< 3,300
and not a
Subpart H
system)
Sample must be collected during the warmest month of the year.
The operator places a copy of the monitoring plan on file in the treatment plant and at the system offices,
for inspection by the public and the Primacy Agency. On January 1, 2004, the operator begins to monitor
in accordance with the plan. On March 31,2004, at the end of the 1st quarter of 2004, the records show
that the appropriate data for all samples required under the terms of the monitoring plan have been
collected, analyzed and recorded. Compliance is calculated based upon the requirements of the
monitoring plan and the appropriate information is submitted to the Primacy Agency on April 10,2004.
Example #27 Decision
System EE is in compliance with the provisions of the Stage 1 DBPR regarding monitoring plans because
the operator prepared and implemented the plan prior to January 31, 2004. Since System EE serves less
than 3,300 people and is not a Subpart H system, and since the Primacy Agency has not directed the
system to do so, the operator is not required to submit a copy of the monitoring plan to the Primacy
Agency.
Public Notice Requirement
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirement
Although System EE is in compliance with the Stage 1 DBPR regarding monitoring plans, the system
must routinely report the information included in Table 2-35 to the Primacy Agency. Please refer to 40
CFR 141.134 for TTHM / HAAS reporting requirements.
January 2003
Page 2 - 82
Stage 1 DBPR Reporting Guidance
-------
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
2.4.1.2 Failure to Submit Monitoring Plan to Primacy Agency M&R Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, page 4 & 9
Section IV-D, page 34
Cross-reference to Rule:
40CFR141.132(f)
Table 2-57. Monitoring Plan - Monitoring and Reporting Violation
Violation
Code
27
Contaminant
Code
0400
Violation Description
For Sub part H systems serving more than 3,300 people, a failure to submit
copy of monitoring plan to Primacy Agency no later than the date of the 1st
report required under 40 CFR141.134.
a
Example System Description - System FF
System FF Summary
Population Served: 100,000
Source #1: Surface water
Treatment #1: Conventional filtration, chlorine
Source #2: Groundwater under the direct influence
Treatment: Membrane filtration, chlorine
System FF is a large Subpart H community water system serving 100,000 people that uses surface water
and ground water under the direct influence of surface water. The surface water source is treated with a
conventional filtration plant and the GWUDI source is membrane filtered. All sources are disinfected
with chlorine. The system is required to monitor according to 40 CFR141.130. The system utilizes two
plants known as TP 1 and TP 2.
Any system required to monitor under the provisions of the Stage 1 DBPR is required to develop and
implement a monitoring plan. System FF's certified operator must prepare a plan including at least the
elements contained in 40 CFR141.132(f). He must prepare the system's monitoring plan within 30 days
of the effective date of the rule as described in 40 CFR141.130(b). According to 40 CFR141.130(b)(l)
the effective date of the rule for System FF is January 1, 2002. The monitoring plan must be completed
no later than January 31, 2002.
Example #28 - Failure to Submit a Monitoring Plan
On December 31, 2001, System FF's operator completes the monitoring plan and includes all of the
elements described in 40 CFR141.132(f). A copy is placed on file at the treatment plant and at the
system offices, for inspection by the public and the Primacy Agency. On January 1, 2002, he begins to
Stage 1 DBPR Reporting Guidance Page 2 - 83 January 2003
-------
monitor in accordance with the plan. Table 2-58 summarizes System FF's monitoring requirements. On
March 31, 2002, at the end of the 1st quarter of 2002, the records show that he has collected, analyzed and
recorded the appropriate data for all samples required under the terms of the monitoring plan. He
calculates compliance based upon the requirements of the monitoring plan and submits the appropriate
compliance information to the Primacy Agency within 10 days after the end of the quarter (April 10,
2002). However, System FF does not submit their monitoring plan to the Primacy Agency along with the
report submitted by April 10, 2002.
Table 2-58. System FF Monitoring Summary
PARAMETER
OR
TASK
Disinfectants:
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distributio
n
System
Distribution
System
Daily
Monthly Quarterly
Annually
or
less than
annually
Chlorine /
Chloramines
X
X
DBPs:
| TTHM /HAA5
DBP Precursors
X
X
Paired TOC
Alkalinity (as
CaCO3)
SUVA*
Monitoring Plan
REQUIRED
X
X
X
YES NO SU
TO
x 1 SP
X
X
X
EMIT MONITORING PLAN
> PRIMACY AGENCY BY
ECIFIC DATE
YES NO
X
* Optional- Alternative compliance criteria of 40 CFR 141.135
Example #28 Decision
System FF is in violation of the Stage 1 DBPR for failing to submit its monitoring plan to the Primacy
Agency by April 10, 2002, even though the plan was prepared and implemented properly. Subsequently,
the Primacy Agency receives the monitoring plan on July 1, 2002.
Public Notice Requirements
40 CFR141.201 does not require that System FF provide public notice of this violation. Primacy
Agencies may require Tier 3 public notice at their discretion.
January 2003
Page 2 - 84
Stage 1 DBPR Reporting Guidance
-------
System Reporting Requirements
There are no system reporting requirements for this parameter in this situation.
Primacy Agency to SDWIS/FED Reporting
The appropriate SDWIS/FED Monitoring Plan M&R violation data elements and DTP transactions are
listed below in Exhibit 2.13. SDWIS Reporting Code: 27/0400.
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
C 1 1 0 1 Violation ID Qualifier 2
C1103 Contaminant code 0400
C1105 Violation Type code 27
Cl 107 Compliance Period Begin Date
C1201 Enforcement ID Qualifier 2
C1203 Enforcement Date
C1205 Follow-up Action SOX (State Action- compliance achieved)
Y5000 Associated Violation ID Violation ID
DTP Transactions:
1-2
Dl
Dl
Dl
El
El
El
3-11
GA1234579
GA1234579
GA1234579
GA1234579
GA1234579
GA1234579
12-18
0200005
0200005
0200005
0200001
0200001
0200001
19-25
26
I
I
I
I
I
I
27-31
C1103
C1105
C1107
C1203
C1205
Y5000
32-71
0400
27
20020410
20020701
SOX
0200005
72-74
75-80
Exhibit 2.13 Monitoring Plan Monitoring and Reporting Violation and RTC Data
Element Table and DTF Transactions
Stage 1 DBPR Reporting Guidance
Page 2 - 85
January 2003
-------
2.4.2 Type 27/0999: Chlorine Monitoring and Reporting Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, pages 4 and 10
Section IV-D, page 19
Appendix D, Attachments 1-5
Cross-reference to Rule:
40CFR141.132(c)(l)
Table 2-59. Chlorine Monitoring and Reporting Violation
Violation Contaminant Violation Description
Code Code
27
0999
Major: A failure to collect, analyze and report 90% of the required samples
Minor: Collecting, analyzing and reporting 90% to 99% of the required
samples
General Discussion of Chlorine M&R Violations
Violations are characterized as either Major or Minor. A major chlorine monitoring violation occurs
when there is a failure to collect and report at least 90% of the required chlorine samples. A minor
monitoring and reporting violation is incurred by a system that does not collect and report 100% of the
required samples, however, it does collect and report between 90% and 99% of the required chlorine
samples. Primacy Agencies report chlorine M&R violations to SDWIS on a quarterly basis. The
violation begin date is entered as the 1st day of the quarter in which one or more samples are missed and
the violation end date recorded as the last day of the quarter in which those samples are missed.
Example System Description - System G
System G is a large Subpart H community water system using surface water and serving 12,500 people
that uses a conventional filtration plant and disinfects with chlorine. System G has only the one plant and
source. Under the continuing provisions of the Total Coliform Rule, System G is required to take at least
10 total coliform samples per month in its distribution system in compliance with an approved coliform
sample siting plan.
System G Summary
Population Served: 12,500
Source: Surface water
Treatment: Conventional filtration, chlorine
Any Subpart H system serving 10,000 or more people adding a chemical disinfectant (e.g., chlorine) must
comply with the provisions of the Stage 1 DBPR on January 1, 2002. The Stage 1 DBPR requires
systems to monitor for chlorine residual at each location in the distribution system and at the same
frequency as total coliform monitoring. System G's certified operator collects and analyzes at least ten
samples per month at locations and times described in the system's monitoring plan. Table 2-60 is a
summary of System G's monitoring requirements.
January 2003 Page 2 - 86 Stage 1 DBPR Reporting Guidance
-------
Table 2-60. System G Monitoring Summary
PARAMETER
OR
TASK
Disinfectants:
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distributio
n
System
Distribution
System
Daily
Monthly Quarterly
Annually
or
less than
annually
Chlorine /
Chloramines
X
X
DBPs:
| TTHM /HAA5
DBP Precursors:
X
X
Paired TOC
Alkalinity
(asCaCO3)
SUVA*
Monitoring Plan
REQUIRED
X
X
X
YES NO S|J
TO
X SP
X
X
X
EMIT MONITORING PLAN
> PRIMACY AGENCY BY
ECIFIC DATE
YES NO
II
X
* Optional - Alternative compliance criteria of 40 CFR141.135
Example #29 - M&R for Chlorine Major Violation
On March 31, 2002, System G's operator reviews the chlorine monitoring data for the 1st quarter of 2002
and finds that only 21 of the required 30 samples for chlorine were collected duringthe quarter. Since
the only issue is the number of samples collected, no data table is provided for this example.
Example #29 Decision
System G's operator has collected 21 of 30, (21 + 31 x 100 = 70) or 70%, of the required chlorine
samples during the 1st quarter of 2002. This failure is a Major Monitoring & Reporting violation. A
system incurs a major M&R violation for the chlorine MRDL when it fails to collect, analyze and report
at least 90% of the required chlorine samples in any quarter.
Public Notice Requirements
System G must provide Tier 3 public notice of the M&R violation according to the requirements of 40
CFR141.201.
Stage 1 DBPR Reporting Guidance
Page 2 - 87
January 2003
-------
System Reporting Requirements
System G must routinely report the information summarized in Tables 2-22, 2-35, and 2-53 to the
Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
The appropriate SDWIS/FED chlorine M&R violation data elements and DTP transactions are listed
below in Exhibit 2.14. SDWIS Reporting Code 27/0999 flag Major (Y).
Data Elements:
Number
Name
Value or Comment
C0101 PWS-ID
CHOI Violation ID
C1103 Contaminant Code
C1105 Violation Type Code
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date
C1131 Maj or Violation Flag
DTP Transactions:
Qualifier 1
Qualifier 2
0999
27
Must be three months later than C1107
Y or N (Major (Y) is defined as reporting <
90% of required samples, Minor (N) as any
other failure to report, such as failure to
measure chlorine in a total coliform sample)
Exhibit 2.14 Chlorine Major Monitoring Violation Data Element Table and DTF
Transactions
Example #30 - M&R for Chlorine Minor Violation
On June 30, 2002, System G's operator reviews the chlorine monitoring data for the 2nd quarter of 2002.
He finds that he has collected 27 of the necessary 30 chlorine samples for the 2nd quarter. Since the only
issue is the number of samples collected, no data table is provided for this example.
January 2003
Page 2 -
Stage 1 DBPR Reporting Guidance
-------
Example #30 Decision
System G's operator has collected 27 of 30, (27 -^ 30 x 100 = 90) or 90%, of the required chlorine
samples during the 2nd quarter of 2002. This is a Minor Monitoring & Reporting violation. A minor
M&R violation for the chlorine MRDL occurs when a system collects, analyzes and reports between 90 -
99% of the required chlorine samples in any quarter, but not all or 100% of the required samples.
Public Notice Requirements
System G must provide Tier 3 public notice of the M&R violation according to the requirements of 40
CFR141.201.
System Reporting Requirements
System G must routinely report the information summarized in Tables 2-22, 2-35, and 2-53 to the
Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
M&R violations are reported for water systems failing to monitor for (or report the results of monitoring
for) the required number of samples. The appropriate SDWIS/FED chlorine M&R violation data
elements and individual DTP transactions are listed below in Exhibit 2.15. SD WIS Reporting Code
27/0999 flag Minor (N).
Stage 1 DBPR Reporting Guidance Page 2 - 89 January 2003
-------
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C1103 Contaminant Code 0999
C 1 1 05 Violation Type Code 27
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be three months later than C1107
C 1 1 3 1 Maj or Violation Flag YorN (Major (Y) is defined as reporting <
90% of required samples, Minor (N) as any
other failure to report, such as failure to
measure chlorine in a total coliform sample)
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234579
GA1234579
GA1234579
GA1234579
GA1234579
12-18
0200002
0200002
0200002
0200002
0200002
19-25
26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1131
32-71
0999
27
20020401
20020630
N
72-74
75-80
Exhibit 2.15 Chlorine Minor Monitoring Violation Data Element Table andDTF
Transactions
Example #31 - M&R for Chlorine Compliance by the System
On September 30, 2002, System G's operator reviews the chlorine monitoring data for the 3rd quarter of
2002. All of the required chlorine monitoring samples for the 3rd quarter of 2002 have been collected.
Since the only issue is the number of samples collected, no data table is provided for this example.
Example #31 Decision
System G's operator has collected 100% of the required chlorine samples during the 3rd quarter of 2002.
System G is in compliance with the Stage 1 DBPR monitoring and reporting requirements for chlorine
for the 3rd quarter of 2002.
Public Notice Requirement
Because the system is in compliance, no public notice s required for this parameter for this reporting
period.
January 2003
Page 2 - 90
Stage 1 DBPR Reporting Guidance
-------
System Reporting Requirement
Although system G is in compliance with the Stage 1 DBPR for chlorine, the system must routinely
report the information included in Tables 2-22, 2-35, and 2-53 to the Primacy Agency.
Primacy Agency To SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
2.4.3 Type 27/1011: Bromate M&R Violation
Cross-reference to Stage 1 DBPR Implementation Guidance:
Section II, pages 4 and 10
Section IV-D, page 26
Appendix D, Attachment 7
Cross-reference to Rule:
40CFR141.132(b)(3)
Table 2-61. Bromate Monitoring and Reporting Violation
Violation
Code
27
Contaminant
Code
1011
Violation Description
A failure to collect and report 100% of the required samples
Example System Description - System H
System H is a small Subpart H community water system serving 4,700 people that uses surface water and
treats with a softening plant. Both ozone and chlorine are used as disinfectants. System H utilizes one
plant and one source. System H wishes to qualify for a reduced bromate monitoring schedule, reducing
monitoring from once monthly at the entry point to the distribution system to once quarterly at the entry
point to the distribution system from the ozone plant.
System H Summary
Population Served: 4,700
Source: Surface water
Treatment: Softening plant, ozone, chlorine
The Stage 1 DBPR provisions are effective for System H on January 1, 2004. The Stage 1 DBPR
includes a requirement for all systems using ozone to monitor for bromate at the entrance to the
distribution system from each ozone plant. System H's certified operator collects one sample from the
entrance to the distribution system on a monthly frequency, according to the system's bromate
monitoring requirements, which are summarized in Table 2-62.
Stage 1 DBPR Reporting Guidance Page 2 - 91 January 2003
-------
PARAMETER
OR
TASK
Disinfectants:
Table 2-62. System H Monitoring Summary
SAMPLE LOCATION SAMPLE FREQUENCY
Plant Entrance to Distribution Daily Monthly Quarterly
Entrance to
Distribution
System
Distribution
System
Annually
or
less than
annually
Chlorine /
Chloramines
X
X
DBPs:
TTHM /HAA5
Bromate
X
X
X
X
DBP Precursors:
Paired TOC
Alkalinity (as CaCO3)
SUVA*
Magnesium
Hardness*
(as CaCO3)
Bromide**
X
X
X
X
(raw &
treated)
X
(source)
Monitoring Plan | YES NO SUBH
REQUIRED 1OP
X SPEC
X
X
X
X
X
rtIT MONITORING PLAN
RIMACY AGENCY BY
:iFIC DATE
YES NO
I
* Optional -Alternative compliance criteria of40 CFR141.135
** Optional to qualify for reduced monitoring for bromate
The Stage 1 DBPR also includes an option to monitor bromide in source water as a condition of reduced
bromate monitoring. Since System H wishes to qualify for a reduced bromate monitoring frequency, the
certified operator collects and analyzes one sample for bromide from the source water on a monthly
frequency, according to the requirements of the system's monitoring plan. He records the results of both
analytical procedures on the bromate / bromide monitoring form and after one year of monthly
monitoring for both bromate and bromide, calculates an annual arithmetic source water bromide
concentration and compares it to 0.05 mg/L. If the annual average source water bromide concentration is
less than 0.05 mg/L, then the operator may reduce the once monthly bromate monitoring schedule to once
per quarter at the entrance to the distribution system. The operator must continue to collect and analyze
one monthly source water sample for bromide, and must maintain a running annual source water bromide
concentration, calculated on a quarterly basis, that is <0.05 mg/L to retain the reduced bromate
monitoring schedule.
January 2003
Page 2 - 92
Stage 1 DBPR Reporting Guidance
-------
General Discussion of Bromide Monitoring
A failure to monitor for bromide is not a violation of the Stage 1 DBPR. Bromide monitoring is only
required as a pre-requisite to a reduced monitoring schedule for bromate. The consequence of a failure to
monitor for bromide at the location(s) and on the frequency necessary to justify a reduced monitoring
frequency for bromate is the loss of the reduced monitoring frequency privilege and a responsibility to
immediately return to a routine bromate monitoring schedule. The failure to collect, analyze and report
all required bromate samples, during periods when the necessary bromide samples are not collected,
analyzed and reported, is a bromate M&R violation.
Example #32 - M&R for Bromate Major Violation
Table 2-63 summarizes the System H treated water bromate and source water bromide monitoring results
for 2004. On December 15,2004, System H's operator collects the bromate sample at the entrance to the
distribution system and the bromide sample in the source water according to the requirements of the
monitoring plan.
Table 2-63. System H 2004 Treated Water Bromate and Source Water Bromide
Monitoring Results (mg/L)
JAN FEB MAR APR MAY JUN JUL AUG SEPT OCX NOV DEC
Bromate 0.008 0.011 0.009
0.008 0.010 NS 0.015 0.006 0.005 0.005 NS 0.008
NS 0.032 0.045 0.033 0.050 NS 0.041
RAA
0.008
(10)
0.040
(10)
Bromide 0.040 0.035 0.048 0.041 0.037
RAA = Running Annual Arithmetic Average
NS = No Samples Taken
Example #32 Decision
During the 2004 calendar year, System H's operator has failed to collect all of the 12 samples necessary
to fulfill the bromate monitoring requirements of the rule. After the 2nd quarter failure to collect a June
sample and after the 4th quarter failure to collect a November sample, System H's monitoring record
would result in Major M&R violations of the Stage 1 DBPR (for both quarters), since the operator failed
to collect and analyze 100% of the required samples. System H is not eligible for a reduction in
monitoring frequency because the system did not collect one full year of bromide samples. SDWIS
Reporting Code 27/1011 flag Major.
Public Notice Requirements
System H must provide Tier 3 public notice of the M&R violation according to the requirements of 40
CFR141.201.
System Reporting Requirements
System H must routinely report the information summarized in Tables 2-13, 2-22, 2-35, and 2-53 to the
Primacy Agency.
Stage 1 DBPR Reporting Guidance
Page 2 - 93
January 2003
-------
Primacy Agency to SDWIS/FED Reporting
Bromate M&R violations are reported quarterly to SDWIS. The report of a violations begins on the 1st
day of the quarter in which the system fails to collect, analyze or report one or more of the required
samples. The violation end date is the last day of the quarter in which the system fails to collect, analyze
or report one or more of the required samples. This PWS failed to take the required bromate samples in
June, 2004, representing one quarter's monitoring and reporting violation. The violation has a begin date
of April 1, 2004, and an end date of June 30, 2004. In addition, the PWS failed to take the required
samples in November, 2004 resulting in another monitoring and reporting violation with a begin date of
October 1, 2004 and an end date of December 31, 2004. Both violations should be reported to EPA.
Since EPA considers these violations to be major, SDWIS/FED will default the major violation flag to
"Y". M&R violations are reported for water systems failing to monitor for (or report the results of
monitoring for) the required number of samples. The appropriate SDWIS/FED bromate M&R violation
data elements and individual DTP transactions for the 2nd quarter of 2004 are listed below in Exhibit
2.16. A similar M&R violation is necessary to report the failure to sample in November of 2004 forthe
4th quarter.
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C 1 1 03 Contaminant Code 1011
C1105 Violation Type Code 27
Cl 107 Compliance Period Begin Date
C1109 Compliance Period End Date Must be three months later than
C1131 Major Violation Flag "Y"
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234579
GA1234579
GA1234579
GA1234579
GA1234579
12-18
0400001
0400001
0400001
0400001
0400001
19-25
26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1131
32-71
1011
27
20040401
20040630
Y
72-74
C1107
75-80
Exhibit 2.16 Bromate Major Monitoring and Reporting Violation Data Element
Table and DTF Transactions
January 2003
Page 2 - 94
Stage 1 DBPR Reporting Guidance
-------
Example #33 - M&R for Bromate Major Violation Spanning Two Calendar Years
Table 2-64 summarizes the treated water bromate and source water bromide monitoring for calendar year
2005. During 2005, SystemH's operator collects the bromate sample at the entrance to the distribution
system and the bromide sample in the source water according to the requirements of the monitoring plan.
Example #33 Decision
After the 4th quarter of 2005, the system's monitoring data shows that it is in compliance with the M&R
requirements for bromate.
Additionally, as of November 2005, as the data in Tables 2-63 and 2-64 forthe December 2004 to
November 2005 RAA show, the operator has documented 12 months of source water bromide
concentrations which demonstrate that the bromide concentrations are <0.05 mg/L. The operator is
allowed to begin quarterly treated water bromate monitoring. However, he must continue the monthly
source water bromide monitoring and those data must continue to show that the source water bromide
concentration is <0.05 mg/L. For discussion purposes, in the event that the operator fails to collect and
analyze the monthly source water bromide samples, he must immediately resume a monthly bromate
monitoring schedule. Because the water system failed to take bromate samples in June 2004 and in
November 2004 (see Table 2-63), the available samples should be used to determine compliance with the
bromate MCL, until the full 12 months of data are available.
Table 2-64. System H 2005 Treated Water Bromate and Source Water Bromide
Monitoring Results (mg/L)
JAN FEE MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC
Bromate 0.011 0.008 0.008 0.009 0.011 0.009 0.015 0.006 0.005 0.005 0.005 0.008
Bromate RAA Dec 2004 - Nov 2005: (0.008 + 0.011 + 0.008 + 0.008 + 0.009 + 0.011 + 0.009 + 0.015 + 0.006
0.005+ +0.005 + 0.005)= 0.1 / 12 = 0.008
Bromate RAA 2005: (0.011 +0.008 + 0.008 + 0.009 + 0.011 +0.009 + 0.015 + 0.006 + 0.005 + 0.005 + 0.005 +
0.008) = 0.01 /12 = 0.008
Bromide 0.038 0.040 0.041 0.048 0.037 0.037 0.032 0.045 0.033 0.050 0.041 0.035
Bromide RAA Dec 2004 - Nov 2005: (0.041 + 0.038 + 0.040 + 0.041 + 0.048 + 0.037 + 0.037 + 0.032 + 0.045
0.033 + 0.050 + 0.041)= 0.0483 / 12 = 0.04
Bromide RAA 2005: (0.038 + 0.040 + 0.041 + 0.048 + 0.037 + 0.037 + 0.032 + 0.045 + 0.033 + 0.050 + 0.041
0.035) = 0.477/12 = 0.04
RAA = Running Annual Arithmetic Average of previous 12 monthly (average) values
Public Notice Requirement
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
Stage 1 DBPR Reporting Guidance Page 2 - 95 January 2003
-------
System Reporting Requirement
Although System H is in compliance with the Stage 1 DBPR for bromide monitoring, the system must
routinely report the information included in Tables 2-13, 2-22, 2-35, and 2-53 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
2.4.4 Type 27/1006: Chloramines M&R Violation
Cross-reference to Stage 1 DBPR Implementation Guidance:
Section II, pages 4 & 9
Section IV-D, page 19
Appendix D, Attachments 1, 2,3, 4 and 5
Cross-reference to Rule:
40CFR141.132(c)(l)
Table 2-65. Chloramines Monitoring and Reporting Violation
Violation Contaminant Violation Description
Code Code
27
1006
Major: A failure to collect, analyze and report at least 90% of the required
samples
Minor: Collecting, analyzing and reporting at least 90%, but between 90%
and 99% of the required samples
Example System Description - System J
System J is a small community water system that serves 1,250 people and uses only ground water. The
system supplies water treated with chloramines for disinfection. System J operates only one treatment
plant from which water enters the distribution system.
System J Summary
Population Served: 1,250
Source: Groundwater
Treatment: Chloramine
System J is a small (<10,000 people) ground water system for which the provisions of the Stage 1 DBPR
are effective on January 1, 2004. The Stage 1 DBPR includes a requirement for all systems using
chloramines to monitor for residual cMoramine disinfectant (combined or total chlorine residual) at the
same points in the distribution system and at the same time and place as total coliform monitoring.
System J's certified operator collects and analyzes one sample for chloramines at each total coliform
monitoring site, according to the requirements of the system's monitoring plan. Table 2-66 is a summary
of System J's monitoring requirements. System J is required to take two (2) total coliform samples in the
distribution system per month and therefore the operator takes two chloramines samples per month,
recording the data on a disinfectant residual monitoring form.
January 2003 Page 2 - 96 Stage 1 DBPR Reporting Guidance
-------
Table 2-66. System J Monitoring Summary
PARAMETER
OR
TASK
Disinfectants:
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distributio
n
System
Distribution
System
Daily Monthly Quarterly
DBPs:
Annually
or
less than
annually
Chlorine /
Chloramines
X
X
TTHM /HAA5
X
X1
Monitoring Plan
REQUIRED
YES
X
NO
SUBMIT MONITORING PLAN
TO PRIMACY AGENCY BY
SPECIFIC DATE
YES
NO
X
(< 3,300
served
and not a
Subpart H
system)
Sample must be collected during the warmest month of the year.
Example #34 - M&R for Chloramines Compliance Over 12 Months
Table 2-67 summarizes the chloramine monitoring results for 2004. On December 15,2004, System J's
operator collects and analyzes the two chloramine samples in the distribution system.
Table 2-67. System J 2004 Chloramine Monitoring Results - mg/L as C12
JAN FEE MAR APR MAY JUN JUL AUG SEPT OCX NOV DEC RAA
Site#l 1.1 1.3 1.1 1.5 1.1 1.4 1.0 1.2 1.2 1.2 1.3 1.1 NA
Site #2
0.9
0.9
1.0
1.3
1.1
1.2
1.0
1.0
1.1
0.9
1.1
1.0
NA
System 1.0 1.1 1.1 1.4 1.1 1.3 1.0 1.1 1.2 1.1 1.2 1.1 1.1
Monthly
Average
RAA = Running Annual Arithmetic Average of previous 12 monthly average values
Example #34 Decision
System J's operator has completed the 1st year of chloramine monitoring and the data show that the
system is in compliance with the M&R requirements for chlorarrines since 100% of the required samples
were taken. Additionally, at the end of the 1st year of monitoring (4 quarters of monitoring) System J is
in compliance with the MRDL because the arithmetic average of the twelve (12) monthly average
chloramine values does not exceed the MRDL of 4.0 mg/L established by the Stage 1 DBPRfor
Stage 1 DBPR Reporting Guidance
Page 2 - 97
January 2003
-------
chloramines. During the 1st full year of monitoring, the operator was able to determine that System J was
in compliance with the MRDL after each quarter by summing the available monthly arithmetic average
chloramine concentrations, assuming zero values for any months for which monitoring had not yet
occurred, and dividing the result by twelve. After any quarter when the result exceeds 4.0 mg/L, a
violation of the MRDL is defined.
Public Notice Requirement
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System J is in compliance with Stage 1 DBPR for chloramines, the system must routinely
report the information included in Table 2-35 to the Primacy Agency. Please refer to 40 CFR 141.134
for TTHM /HAA5 reporting requirements.
Primacy Agency To SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Example #35 - M&R for Chloramines Major Violation
Table 2-68 summarizes the chloramine monitoring for the 1st and 2nd quarters of 2005. On January 16,
2005, the operator is called to active military duty for 90 days. Whenhe returns to work on April 16,
2005, he finds that, during his absence, chloramine samples were collected and analyzed only at site #1.
He also finds that no report regarding the 1st quarter of 2005 was filed with the Primacy Agency by April
10. System J's operator immediately collects and analyzes the correct samples for the month of April,
and submits a report of the available data for the 1st quarter of 2005 to the Primacy Agency on April 20,
2005.
Table 2-68. System J 2005 Chloramine Monitoring Results - mg/L as C12
JAN FEE MAR APR MAY JUN JUL AUG SEPT OCX NOV DEC RAA
Site#l 1.1 4.7 3.3 3.0 1.9 1.4
Site #2
System
Monthly
Average
NS
1.1
NS
4.7
NS
3.3
1.3
2.2
1.8 1.1
1.9 1.3
RAA 1.6 1.7
RAA = Running Annual Arithmetic Average of previous 12 monthly average values
NS = No sample collected / analyzed
January 2003 Page 2 - 98 Stage 1 DBPR Reporting Guidance
-------
Example #35 Decision
During the 1st quarter of 2005, three of six (50%) of the required samples for chloramines were collected
and analyzed. This results in a major chloramines M&R violation for System J for the 1st quarter of 2005
since there was a failure to collect and report at least 90% of the required chloramine samples. During
the 2nd quarter of 2005, the operator collected 100% of the required samples, and met the M&R
requirements for chloramine monitoring. Additionally, the data shows that System J remains in
compliance with the MRDL established for chloramines, because the running annual arithmetic averages
calculated at the end of the 1st quarter of 2005 do not exceed 4.0 mg/L. The RAAs are calculated using
the available data points and will produce a record of compliance or noncompliance with the MRDL.
However, the missing data from all RAA periods that would utilize the 1st quarter of 2005 as part of the
four quarter set will produce a M&R violation that spans the period from three quarters prior to the
quarter of missing data, to three quarters past the quarter of missing data.
Public Notice Requirements
System J must provide Tier 3 public notice of the chloramines M&R violation after the 1st quarter
according to the requirements of 40 CFR141.201, and continue to do so until the 1st quarter of 2006,
when System J has the potential to have four consecutive quarters of data.
System Reporting Requirements
System J must routinely report the information summarized in Table 2-35 to the Primacy Agency. Please
refer to 40 CFR 141.134 for TTHM / HAAS reporting requirements.
Primacy Agency to SDWIS/FED Reporting
System J must report a major M&R violation for the 1st quarter of 2005. SDWIS Reporting Code
27/1006 flag Major.
The appropriate SDWIS/FED chlorine M&R violation data elements and individual DTP transactions are
listed below in Exhibit 2.17.
Stage 1 DBPR Reporting Guidance Page 2 - 99 January 2003
-------
Data Elements:
Number
Name
Value or Comment
C0101 PWS-ID
CHOI Violation ID
C1103 Contaminant Code
C1105 Violation Type Code
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date
C1131 Maj or Violation Flag
DTP Transactions:
Qualifier 1
Qualifier 2
1006
27
Must be three months later than C1107
Y or N (Major is defined as reporting < 90%
of required samples, Minor as any other failure
to report, such as failure to measure chlorine
in a total coliform sample)
1-2
Dl
3-11
GA1234579
12-18
0500001
19-25
26
I
27-31
C1103
32-71
1006
72-74
75-80
Dl
GA1234579
0500001
I
C1105
27
Dl
GA1234579
0500001
C1107
20050101
Dl
GA1234579
0500001
C1109
20050331
Dl
GA1234579
0500001
C1131
Y
Exhibit 2.17 Chloramines Minor Monitoring Violation Data Element Table and
DTF Transactions
2.4.5 Type 27/1009: Chlorite M&R Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, pages 4 & 11
Section IV-D, page 27
Appendix D, Attachment 6
Cross-reference to Rule:
40CFR141.132(b)(2)
Violation
Code
Table 2-69. Chlorite Monitoring and Reporting Violation
Violation Description
Contaminant
Code
27
1009
Major: A failure to collect, analyze and report at least 90% of the daily
samples at the entrance to the distribution system or any required 3-sample set
in the distribution system.
Minor: Collecting, analyzing and reporting at least 90%, but between 90%
and 99% of the required samples
January 2003
Page 2-100
Stage 1 DBPR Reporting Guidance
-------
Example System Description - System GG
System GG is a large Subpart H community water system serving 265,000 people that uses surface water.
The water is treated with a single conventional filtration surface water treatment plant that uses chlorine
dioxide for oxidation and chlorine as a final disinfectant. System GG has one treatment plant and one
entry point to the distribution system.
System GG Summary
Population Served: 256,000
Source: Surface water
Treatment: Conventional filtration, chlorine dioxide, chlorine
System GG is a large (>10,000 people) Subpart H system for which the provisions of the Stage 1 DBPR
are effective on January 1, 2002. The Stage 1 DBPR includes a requirement for all systems using
chlorine dioxide, for either disinfection or oxidation, to monitor for chlorite on a daily basis at the
entrance to the distribution system. System GG's certified operator collects one sample for chlorite, each
day, at the entrance to the distribution system, according to the requirements of the system's monitoring
plan. Chlorite samples are analyzed by a certified laboratory. Table 2-70 presents a summary of System
GG's monitoring requirements.
System GG's certified operator records the chlorite analysis result each day on a chlorite monitoring
form. In addition to the routine daily monitoring, the operator must also collect and analyze a 3-sample
set of samples for chlorite once per month in the distribution system at locations described in System
GG's monitoring plan. In the event that any daily sample collected at the entrance to the distribution
system is greater than 1.0 mg/L, the operator must collect a 3-sample set from the distribution system on
the following day. These additional compliance assessment samples for chlorite must be collected at
sites that are described in System GG's monitoring plan and that meet the requirements of 40
CFR141.132(b)(2)(ii). A system that completes additional compliance assessment sampling in the
distribution system on the day after a daily sample that exceeds the MCL may substitute that 3-sample set
monitoring for the required single monthly 3-sample set.
Example #36 - M&R for Chlorite
Table 2-70 summarizes the chlorite monitoring results for January, 2002. On January 31, 2002, System
GG's operator collects and analyzes the daily routine entrance to the distribution system sample for
chlorite. He records the results on the chlorite monitoring form.
Stage 1 DBPR Reporting Guidance Page 2-101 January 2003
-------
Table 2-70. System GG Monitoring Summary
PARAMETER
OR
TASK
Disinfectants:
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distributio
n
System
Distribution
System
Daily
Monthly Quarterly
Annually
or
less than
annually
Chlorine / Chloramines
Chlorine Dioxide
X
X
X
X
X
A distributi on system 3- samp le set must be collect ed
the day following any exceedanceof 0.8 mg/Lat the
entrance to the distribution system
DBPs:
TTHM /HAAS
Chlorite
(grab)
(3-sample set)
(3-sample set)
X
X
X
X
X
X
X
Distribution system 3-sample set must be collected on
the day following any daily sample that exceeds 1.0
mg/L at the entran ce to the distri bution system
DBP Precursors:
Paired TOC
Alkalinity (as CaCO3)
Monitoring Plan
REQUIRED
X
X
YES NO SL
U
X SP
X
X
fBMIT MONITORING PLAN
) PRIMACY AGENCY BY
ECIFIC DATE
YES NO
*
January 2003
Page 2-102
Stage 1 DBPR Reporting Guidance
-------
Table 2-71. System GG January 2002 Chlorite Monitoring Results (mg/L)
[Sunday Monday
Tuesday Wednesday
day 1 day 2
0.5 mg/L 0.6 mg/L
Thursday
day 3
NS
Friday
day 4
0.9 mg/L
Saturday
day 5
1.0 mg/L
day 6
0.7 mg/L
day 13
NS
0.9 mg/L
0.8 mg/L
0.8 mg/L
day 20
1.4 mg/L
day 27
0.8 mg/L
day 7
NS
day 14
1.0 mg/L
day 21
0.8 mg/L
0.8 mg/L
0.7 mg/L
0.7 mg/L
day 28
NS
day 8
NS
day 15
0.6 mg/L
day 22
0.7 mg/L
day 29
NS
day 9
1.1 mg/L
day 16
0.6 mg/L
day 23
0.6 mg/L
day 30
1.0 mg/L
day 10
0.9 mg/L
0.9 mg/L
0.8 mg/L
0.7 mg/L
day 17
0.7 mg/L
day 24
0.7 mg/L
day 31
day 11
0.8 mg/L
day 18
0.9 mg/L
day 25
0.7 mg/L
day 12
1.1 mg/L
day 19
0.9 mg/L
day 26
0.8 mg/L
0.9 mg/L
Note: data in box to left is routine daily entrance to the distribution system, data to right is 3-sample distribution
system set
NS = no sample collected /analyzed
Example #36 Decision
A review of System GG's chlorite monitoring data for January 2002 discloses a chlorite M&R violation.
System GG fed chlorine dioxide continuously throughout the month, so the operator was required to take
a minimum of 31 routine daily samples and at least one routine monthly 3-sample set. Two additional 3-
sample sets were required due to entry point results, bringing the total number of required samples to 40
(31 daily and 9 additional samples). He actually took 25 of the monthly routine samples and three 3-
sample sets of distribution system samples. He collected and analyzed 34 of 40 required samples, or 85
%. That documents a major M&R violation for chlorite (failure to collect and report at least 90% of
required chlorite samples). For discussion purposes, although the operator failed to take several samples
during the month, a review of the data show that there was no chlorite MCL violation during the month.
The arithmetic averages of each 3-sample sets taken on day 10 (arithmetic average = 0.8 mg/L), day 13
(arithmetic average = 0.8 mg/L) and day 21 (arithmetic average = 0.7 mg/L) are included in the
calculation to determine compliance with the MCL. Since no result exceeds the 1.0 mg/L MCL for
chlorite, there is no violation of the MCL in January 2002.
If a PWS fails to take a three sample set, either for the once-a-month sample, or as a result of an entry
point exceedance, each of the samples required (a three sample set counts as 3 samples) will be used, as
well as each of the samples missed, for computing whether the violation is a major or minor.
Stage 1 DBPR Reporting Guidance
Page 2 - 103
January 2003
-------
Public Notice Requirements
System GG must provide Tier 3 public notice of this chlorite M&R violation according to the
requirements of 40 CFR141.201.
System Reporting Requirements
System GG must routinely report the information summarized in Tables 2-6, 2-35, 2-45, and 2-53 to the
Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
The appropriate SDWIS/FED chlorite M&R violation data elements and individual DTP transactions are
listed below in Exhibit 2.18. SD WIS Reporting Code 27/1009 flag Major.
Data Elements:
Number Name Value or Comment
C0101 PWS-ID
CHOI Violation ID
C 1 1 03 Contaminant Code
C 1 1 05 Violation Type Code
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date
C 1 1 3 1 Maj or Violation Flag
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234579
GA1234579
GA1234579
GA1234579
GA1234579
12-18
0200001
0200001
0200001
0200001
0200001
19-25
26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1131
Qualifier 1
Qualifier 2
1009
27
Y or N (Major is defined as reporting < 90%
of required samples, Minor as any other failure
to report)
32-71 72-74 75-80
1009
27
20020101
20020131
Y
Exhibit 2.18 Chlorite M&R Violation Data Element Table and Individual DTF
Transactions
January 2003
Page 2-104
Stage 1 DBPR Reporting Guidance
-------
2.4.6 Type 27/1008: Chlorine Dioxide M&R Violation
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, pages 4 & 10
Section IV-D, page 20
Appendix D, Attachment 6
Cross-reference to Rule:
40CFR141.132(c)(2)
Table 2-72. Chlorine Dioxide Monitoring and Reporting Violation
Violation
Code
27
Contaminant
Code
1008
Violation Description
A failure to collect and report 100% of the required samples
Example System Description - System HH
System HH is a small community water system serving 900 people that uses ground water. The system
supplies water treated with chlorine dioxide for oxidation of iron and manganese on a routine basis.
System HH utilizes one treatment plant and it uses chlorine to maintain a disinfectant residual in the
distribution system. There are no disinfection addition points after the entrance to the distribution
system.
System HH Summary
Population Served: 900
Source: Ground water
Treatment: Chlorine dioxide, oxidation for iron/manganese removal
System HH is a small (<10,000 people) community water system for which the provisions of the Stage 1
DBPR regarding the use of chlorine dioxide are effective on January 1, 2004. The Stage 1 DBPR
includes a requirement for all systems using chlorine dioxide, for either disinfection or oxidation, to
monitor for chlorine dioxide according to the requirements of 40 CFR141.132(c)(2) on a daily basis at
the entrance to the distribution system. System HH's certified operator collects and analyzes one sample
for chlorine dioxide each day, at the entrance to the distribution system, according to the requirements of
the system's monitoring plan. Table 2-73 presents a summary of System HH's Stage 1 monitoring
requirements.
The operator records the chlorine dioxide analysis result (as mg/L C1O2) each day on a chlorine dioxide
monitoring form. In addition to the daily monitoring, the system must collect and analyze three chlorine
dioxide samples, referred to as the 3-sample set, in the distribution system the day following a daily
sample that exceeds 0.8 mg/L. The three samples collected in the distribution system must be from
locations and at times described in the monitoring plan and that meet the requirements of 40
CFR141.132(c)(2)(ii). In this example, the three samples must be collected as close to the 1st customer as
possible, at intervals of at least six hours. There is no opportunity for a reduced monitoring frequency for
chlorine dioxide.
Table 2-73. System HH Monitoring Summary
Stage 1 DBPR Reporting Guidance Page 2-105 January 2003
-------
PARAMETER
OR
TASK
Disinfectants:
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distributio
n
System
Distribution
System
Daily Monthly Quarterly
Annually
or
less than
annually
Chlorine / Chloramines
Chlorine Dioxide
X
X
X
X
X
A distributi on system 3- samp le set must be collect ed
the day folowing any exceedanceof 0.8 mg/Lat the
entrance to the distribution system
DBPs:
TTHM /HAAS
X
X
Chlorite
(grab)
X
X
(3-sample set)
(3-sample set)
X
X
X
A distribution system 3-sample set must be collected on
the day following any daily sample that exceeds 1.0
mg/L at the entran ce to the distri bution system
Monitoring Plan
EQUIRED
YES NO SUBMIT MONITORING PLAN
TO PRIMACY AGENCY BY
SPECIFIC DATE
YES
NO
X
(< 3,300
served and
not a
Subpart H
system)
Example #37 - M&R for Chlorine Dioxide
Table 2-74 summarizes System HH's chlorine dioxide monitoring results for March, 2004. On March
31, 2004, System HH's certified operator collects and analyzes the required daily entrance to the
distribution system sample for chlorine dioxide. He records the results on the chlorine dioxide
monitoring form.
January 2003
Page 2 - 106
Stage 1 DBPR Reporting Guidance
-------
Table 2-74. March 2004 Chlorine Dioxide Monitoring Results mg/LasC!O2
Sunday Monday Tuesday Wednesday Thursday Friday Saturday
Day 1
0.7 mg/L
Day 2
NS
Day 3
1.0 mg/L
Day 4
0.9 mg/L
0.9 mg/L
0.8 mg/L
0.5 mg/L
DayS
0.9 mg/L
0.8 mg/L
0.7 mg/L
0.5 mg/L
Day 6
0.7 mg/L
0.7 mg/L
0.7 mg/L
0.5 mg/L
Day?
0.7 mg/L
Day 14
0.7 mg/L
Day 21
0.4 mg/L
Day 28
0.8 mg/L
DayS
0.6 mg/L
Day 15
0.6 mg/L
Day 22
0.7 mg/L
Day 29
0.9 mg/L
Day 9
NS
Day 16
NS
Day 23
NS
Day 30
0.8 mg/L
0.8 mg/L
0.7 mg/L
0.6 mg/L
Day 10
NS
Day 17
NS
Day 24
NS
Day 31
0.7 mg/L
Day 11
0.8 mg/L
Day 18
0.7 mg/L
Day 25
0.8 mg/L
Day 12
0.7 mg/L
Day 19
0.7 mg/L
Day 26
0.7 mg/L
Day 13
0.5 mg/L
Day 20
0.3 mg/L
Day 27
0.6 mg/L
Note: the values to the left of each day square are daily routine monitoring (entrance to the distribution system)
results and the values to the right of the day square are additional monitoring in the distribution system, required the
day following a day when any daily routine sample exceeds the 0.8 mg/L MRDL for chlorine dioxide.
NS = no sample collected / analyzed
Example #37 Decision
A review of System HH's chlorine dioxide monitoring data for March 2004, shows that, although the
operator was required to collect and report 31 routine daily samples for chlorine dioxide at the entrance
to the distribution system and 12 distribution system samples, for a total of 43 samples, he failed to take
seven (7) daily samples. This failure to take 100% of the required chlorine dioxide samples is an M&R
violation, that must be reported to the Primacy Agency within 10 days of the end of the quarter (April 10,
2004), along with the M&R violation summary for January 2004 and February 2004.
Additional review of the data shows that the operator must report that the MRDL was exceeded twice
during March 2004. System HH must report an acute violation of the MRDL for chlorine dioxide for
March 4th, because the MRDL of 0.8 mg/L is exceeded by the combination of the March 3, 2004 routine
daily sample (1.0 mg/L) and also by one or more of the March 4, 2004 additional distribution system
samples (0.9 mg/L). System HH's operator must report a 2nd MRDL violation, however, it is identified
as a non-acute violation for March 5th , because none of the additional distribution system samples taken
on March 5, 2004 exceed the MRDL, even though the routine entrance to the distribution system samples
on both days exceed the MRDL value of 0.8 mg/L. Later in the month, on March 29, 2004, the routine
daily entrance to the distribution system sample exceeds the MRDL (0.9 mg/L), however, neither the
March 30, 2004 routine sample nor the three additional distribution system samples for March 30, 2004
exceed the chlorine dioxide MRDL of 0.8 mg/L. For chlorine dioxide, any failure to take samples in the
distribution system the day following an exceedance of the MRDL by an entrance to the distribution
system sample is also considered an MRDL violation. Please see Section 2.2.3 for a discussion of the
chlorine dioxide MRDL reporting requirements.
Public Notice Requirements
Stage 1 DBPR Reporting Guidance
Page 2-107
January 2003
-------
System HH must provide Tier 3 public notice regarding the M&R violations according to the
requirements of 40 CFR141.201.
System Reporting Requirements
System HH must routinely report the information summarized in Tables 2-6, 2-35, and 2-45 to the
Primacy Agency. Please refer to 40 CFR 141.134 for TTHM / HAAS reporting requirements.
Primacy Agency to SDWIS/FED Reporting
The appropriate SDWIS/FED chlorine dioxide M&R violation data elements and individual DTP
transactions are listed below in Exhibit 2.19. SDWIS Reporting Code 27/1008 (M&R Violation).
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C 1 1 03 Contaminant Code 1009
C 1 1 05 Violation Type Code 27
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date
C1112 Severity Indicator Count Number of days not sampled or reported
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234579
GA1234579
GA1234579
GA1234579
GA1234579
12-18
0400001
0400001
0400001
0400001
0400001
19-25
26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1112
32-71
1008
27
20040301
20040331
7
72-74
75-80
Exhibit 2.19 Chlorine Dioxide M&R Violation Data Element Table and Individual
DTF Transactions
January 2003
Page 2 - 108
Stage 1 DBPR Reporting Guidance
-------
2.4.7 Type 27/2456: HAAS M&R Violation and Type 27/2950: TTHM M&R Violation
2.4.7.1 Subpart H at Least 10,000 People
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, pages 4 and 12
Section IV-D, page 21
Appendix D, Attachment 1
Cross-reference to Rule:
40CFR141.132(b)
Violation
Code
Table 2-75. HAAS Monitoring and Reporting Violation
Violation Description
Contaminant
Code
27
2456
Major-Failure to collect & report at least 90% of the required samples
Minor-Collect & report at least 90% and between 90% and 99% of the
required samples (but not all required)
Violation
Code
Table 2-76. TTHM Monitoring and Reporting Violation
Contaminant Violation Description
Code
27
2950
Major-Failure to collect & report at least 90% of the required samples
Minor-Collect & report at least 90% and between 90% and 99% of the
required samples (but not all required)
Example System Description - System JJ
System JJ is a large Subpart H system serving 10,050 people which uses surface water and ground water
determined to be under the direct influence of surface water. All water from the surface water and
GWUDI sources is treated at the same conventional filtration plant Chlorine is used as a disinfectant.
System JJ Summary
Population Served:
Source #1:
Source #2:
Treatment #1:
10,050
Groundwater under the direct influence
Surface water
(serves both sources) conventional filtration, chlorine
The provisions of the Stage 1 DBPR regarding the use of chemical disinfectants are effective for System
JJ on January 1, 2002. The Stage 1 DBPR includes a requirement for all systems using chemical
disinfectants, for either disinfection or oxidation, to monitor for the disinfection byproducts HAA5 and
TTHM. Monitoring is performed according to the requirements of 40 CFR141.132(b) in the distribution
system at a frequency of fourtimes per plant per quarter. System JJ's certified operator collects four
samples for HAAS and for TTHM, as described in the system's monitoring plan, and in conformance
with the sample location descriptions included in 40 CFR141.132(b)(l)(i). Samples are analyzed by a
certified laboratory. Table 2-77 presents a summary of System JJ's Stage 1 monitoring requirements.
Stage 1 DBPR Reporting Guidance
Page 2 - 109
January 2003
-------
Table 2-77. System JJ Monitoring Summary
PARAMETER
OR
TASK
SAMPLE LOCATION
SAMPLE FREQUENCY
Plant
Entrance to
Distributio
n
System
Distribution
System
Daily
Monthly Quarterly
Annually
or
less than
annually
Disinfectants:
Chlorine / Chloramines
DBPs:
X
X
TTHM /HAAS
DBP Precursors:
X
X
Paired TOC
Alkalinity (as CaCO3)
SUVA*
Monitoring Plan
REQUIRED
X
X
X
YES NO SU
TO
X SP
X
X
X
EMIT MONITORING PLAN YES
• PRIMACY AGENCY BY
ECIFIC DATE X
NO
* Optional -Alternative compliance criteria requirement of 40 CFR141.135
The operator records the HAAS and TTHM results on a monitoring form. A reduced monitoring
schedule (one sample per treatment plant per quarter at the distribution system location reflecting
maximum residence time) is allowed after at least one year of routine monitoring for either parameter.
When the source water annual average TOC level, before any treatment, is less than or equal to 4.0 mg/L,
and, when the annual average HAAS or TTHM concentration is less than or equal to 0.030 mg/L for
HAAS and 0.040 mg/L for TTHM (50% of the established MCL) a system may go to reduced
monitoring.
Systems that qualify for reduced monitoring may remain on reduced monitoring as long as the average of
all samples taken in a year (or the result of the one sample taken in a year, for those on annual
monitoring) does not exceed 0.045 mg/L for HAAS and 0.060 mg/L for TTHM. This determination is
made on a quarterly basis. The system must return to routine monitoring the quarter immediately
following a quarter when the system exceeds 0.045 mg/L for HAAS, or 0.060 mg/L for TTHM. The
Primacy Agency may return a system to a routine monitoring schedule at their discretion (40
CFR141.132(b)(l)(iv)).
Example #38 - M&R TTHM and HAAS Calendar Year 2002
Table 2-78 summarizes System JJ's HAAS and TTHM monitoring results for 2002. On December 31,
2002, System JJ's operator reviews the HAAS & TTHM data collected for 2002.
January 2003
Page 2-110
Stage 1 DBPR Reporting Guidance
-------
Example #38 Decision
System JJ has collected and analyzed all of the necessary samples for HAAS and TTHM during the 1st
full year after the applicable date of the rule. The data for system JJ shows that there are no M&R
violations for these parameters (HAAS & TTHM), and there are no MCL violations during this period.
The source water TOC monitoring shows that the annual arithmetic average TOC concentration is 3.7
mg/L, which is <4.0 mg/L, fulfilling one condition for reduced monitoring. However the system may not
reduce monitoring because the RAA HAAS concentration exceeds 0.030 mg/L and the RAA TTHM
concentration exceeds 0.040 mg/L, figures which represent 50% of the MCL values.
Public Notice Requirement
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirement
Although System JJ is in compliance with the Stage 1 DBPR for HAAS and TTHM monitoring, the
system must routinely report the information included in Tables 2-22, 2-35, 2-53 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Example #39 - M&R for HAAS & TTHM 2002 / 2003
Table 2-79 summarizes System JJ's monitoring results for 2003. On June 30, 2003, System JJ's operator
reviews the system's monitoring data for the past year, including the 3rd quarter of 2002, the 4th quarter of
2002 (found in Table 2-78), the 1st quarter of 2003 and the 2nd quarter of 2003 (found in Table 2-79). As
displayed in the Tables, he has calculated the RAA for HAAS, TTHM and source water TOC.
Stage 1 DBPR Reporting Guidance Page 2-111 January 2003
-------
Table 2-78. System JJ 2002 TTHM & HAAS Monitoring Results (mg/L)
Parameter
HAAS
MCL =
0.060
mg/L
HAAS
QAvg
TTHM
MCL =
0.080
mg/L
TTHM
QAvg
TOC
Source
water
TOC
QAvg
JAN
4.0
FEB
5.9
MAR
0.079
0.049
0.062
0.086
0.069
0.069
0.0660.
063
0.055
0.063
5.0
5.0
APR
5.3
MAY
4.6
JUN
0.077
0.044
0.055
0.052
0.057
0.065
0.063
0.059
0.049
0.059
3.9
4.6
JUL
3.3
AUG
3.1
SEPT
0.060
0.051
0.049
0.043
0.051
0.061
0.055
0.053
0.051
0.055
3.0
3.1
OCT
2.2
NOV
2.4
DEC IRAA 1
0.040
0.039
0.033
0.035
0.037 0.054
1 1
0.060
0.054
0.051
0.047
0.053
2.1
2.2
0.058
3.7
3.7
^f.J--m-' o
QAvg = Quarterly arithmetic average value
RAA = Running annual arithmetic average value
Table 2-79. System JJ 2003 TTHM & HAAS Monitoring Results (mg/L)
RAA
Parameter
HAAS
MCL =
0.060 mg/L
HAAS Q Avg
HAAS RAA
TTHM
MCL =
0.080
mg/L
TTHM Q Avg
TTHM RAA
TOC
Source water
QAvg
TOC
RAA
JAN
4.0
FEB
5.9
MAR
0.049
0.029
0.022
0.026
0.031
0.044
0.039
0.036
0.033
0.025
0.033
0.050
5.0
4.9
3.7
APR
5.3
MAY
4.6
JUN
0.037
0.034
0.025
0.022
0.030
0.037
0.065
0.053
0.049
0.049
0.054
0.049
3.9
4.6
3.7
JUL
3.3
AUG
2.9
SEPT
0.020
0.031
0.029
0.023
0.026
0.031
0.031
0.025
0.023
0.021
0.025
0.041
3.0
3.1
3.7
OCT
2.2
NOV
2.4
DEC
0.020
0.019
0.023
0.025
0.022
0.030
0.024
0.021
0.017
0.023
2.1
2.2
QAvg = Quarterly arithmetic average value
RAA = Running annual arithmetic average value
0.027
0.034
3.7
3.7
January 2003
Page 2-112
Stage 1 DBPR Reporting Guidance
-------
Example #39 Decision
Again, System JJ's operator concludes that the system has no M&R violations to report for the period
July 1, 2002 to June 30, 2003. Additionally, the system is in compliance with the MCLs for HAAS
(0.060 mg/L) and TTHM (0.080 mg/L) calculated as an RAA of quarterly average values for the 12
month periods ending March 31,2003 and June 30, 2003.
System JJ is not eligible for reduced monitoring after June 30, 2003, because the system data shows that
it does not meet all conditions specified in 40 CFR141.132(b)(l)(ii). The RAA source water TOC is less
than 4.0 mg/L, however, neither the HAAS nor the TTHM RAA concentrations are below the levels
specified in the rule as a prerequisite for reduced monitoring.
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System JJ is in compliance with the Stage 1 DBPR for TTHM and HAAS, the system must
routinely report the information included in Tables 2-22, 2-35, and 2-53 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
Example #40 - M&R for HAA5 & TTHM Calendar Year 2003
On September 30, 2003 and on December 31, 2003, System JJ's operator reviews the data for the system.
On September 30, 2003, he reviews the data for the 4th quarter of 2002, the 1st quarter of 2003, the 2nd
quarter of 2003 and the 3rd quarter of 2003. On December 31, 2003, he reviews the data for the calendar
year (four quarters) of 2003.
Example #40 Decision
There are no M&R violations and no MCL violations at this time. Since there are no TTHM or HAAS
violations, the water system is in compliance with the rule requirements as they apply to TTHM and
HAAS for these monitoring periods. The operator concludes that the system qualifies for a reduction in
monitoring for HAAS and TTHM, after December 31, 2003, because its RAA source water TOC (3.7
mg/L) is <4.0 mg/L, the RAA HAAS concentration (0.027 mg/L) is less than 0.030 mg/L, and the RAA
TTHM concentration (0.034 mg/L) is less than 0.040 mg/L. The operator is allowed to begin, in the 1st
quarter of 2004, to take the HAAS and TTHM samples on a frequency of once (per treatment plant) per
quarter at the distribution system location reflecting maximum residence time. He can continue to
sample at this reduced frequency, as long as the RAA source water TOC concentration is < 4.0 mg/L, the
HAAS RAA concentration does not exceed 0.045 mg/L and the TTHM RAA concentration does not
exceed 0.60 mg/L. In the 1st quarter following a quarter when these values are exceeded, the system must
return from a reduced monitoring to a routine monitoring schedule.
Stage 1 DBPR Reporting Guidance Page 2-113 January 2003
-------
Public Notice Requirements
Because the system is in compliance, no public notice is required for this parameter for this reporting
period.
System Reporting Requirements
Although System JJ is in compliance with the Stage 1 DBPR forTTHM and HAAS, the system must
routinely report the information included in Tables 2-22, 2-35, and 2-53 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
Because the system is in compliance, no SDWIS/FED reporting is required for this parameter for this
reporting period.
2.4.7.2 Subpart H 500 to 9,999 People
Cross-reference to Stage 1 DBPR Implementation Guidance:
Section II, pages 4 and 12
Section IV-D, page 21
Appendix D, Attachment 2
Cross-reference to Rule:
40CFR141.132(b)
Please see Tables 2-75 and 2-76
Example System Description - System KK
System KK is a small Subpart H system serving 8,900 people (at least 500 people but no more than 9,999
people) to which the requirements of Stage 1 DBPR are applicable on or before January, 2004. The
system uses surface water treated in one conventional filtration plant. The system uses chlorine as a
chemical disinfectant applied at one location and must monitor for the disinfection byproducts HAAS
and TTHM according to the requirements of 40 CFR141.132(b) in the distribution system at a frequency
of once per quarter at the location of maximum residence time.
System KK Summary
Population Served: 8,900
Source: surface water
Treatment: conventional filtration, chlorine
Example #41 - M&R for HAA5 and TTHM Small System Quarterly
Table 2-80 presents a summary of System KK's HAAS and TTHM monitoring results for year 2004.
January 2003 Page 2-114 Stage 1 DBPR Reporting Guidance
-------
Table 2-80. System KK 2004 HAAS and TTHM Monitoring Results (mg/L)
Parameter
HAA5
MCL =
0.060 mg/L
TTHM
MCL =
0.080
mg/L
JAN
FEB
MAR
0.038
0.070
APR
MAY
JUN
NO SAM
NO SAM
JUL
'LE
•LE
AUG
SEPT
0.042
0.068
OCX
NOV
DEC RAA
0.055 0.045
0.070 0.069
On July 1, 2004, system KK's operator reviews the data for the 1st and 2nd quarters of 2004. System KK
did not complete the necessary monitoring of HAAS and TTHM for the 2nd quarter of 2004.
Example #41 Decision
System KK's sampling record shows a Major M&R violation in the 2nd quarter of 2004, resulting from a
failure to take the necessary single sample in that quarter. A Major M&R violation occurs when a system
fails to take at least 90% of the required samples. In this case, when only one sample per quarter is
required, the failure to take it is a Major M&R violation for the quarter. A Major M&R violation for the
2nd quarter of 2004 should be reported to SDWB for both HAAS and TTHM.
Public Notification Requirement
System KK must provide Tier 3 public notice of this HAAS and TTHM monitoring and reporting
violation after the 2nd quarter of 2004, according to the requirements of 40 CFR141.201.
System Reporting Requirement
System KK must routinely report the information summarized in Tables 2-22 and 2-35 to the Primacy
Agency.
Primacy Agency to SDWIS/FED Reporting
The appropriate SDWIS/FED TTHM and HAAS M&R violation data elements and individual DTP
transactions are listed below in Exhibit 2.20. Note that two violations are to be reported; one for HAAS
and the other for TTHM. SDWIS Reporting Code 27/2456 (for HAAS) and 27/2950 (for TTHM).
Stage 1 DBPR Reporting Guidance
Page 2-115
January 2003
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Data Elements:
Number Name
Value or Comment
C101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
Cl 103 Contaminant Code 2456 (for HAAS) or 2950 (for TTHM)
C 1 1 05 Violation Type Code 27
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date 3 months later than C1107
C 1 1 3 1 Maj or Violation Flag Y or N (Major is defined as reporting <90% of
required samples, Minor as any other failure to
report)
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234579
GA1234579
GA1234579
GA1234579
GA1234579
3-11
GA1234579
GA1234579
GA1234579
GA1234579
GA1234579
12-18
0400001
0400001
0400001
0400001
0400001
12-18
0400001
0400001
0400001
0400001
0400001
19-25
19-25
26
I
I
I
I
I
26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1131
27-31
C1103
C1105
C1107
C1109
C1131
32-71
2456
27
20040401
20040630
Y
32-71
2950
27
20040401
20040630
Y
72-74
72-74
75-80
75-80
Exhibit 2.20 TTHM and HAAS M&R Violations Data Element Table and
Individual DTF Transactions
January 2003
Page 2-116
Stage 1 DBPR Reporting Guidance
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2.4.7.3 Subpart H <500 People
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, pages 4 and 12
Section IV-D, page 21
Appendix D, Attachment 3
Cross-reference to Rule:
40CFR141.132(b)
Please see Tables 2-75 and 2-76
If a Subpart H system serving less than 500 people that is required to collect and report one HAAS and
TTHM sample per plant per year fails to collect that sample, the failure results in an M&R violation for
the calendar year in which no sample was collected. The appropriate data elements and DTP transactions
would be as shown in Exhibit 2-20, except the Compliance Period Begin Date, data element Cl 107,
should be entered as January 1 of the appropriate year, and the Compliance Period End Date, data
element Cl 109 should be entered as December 31 of that same year. The M&R violation is a Major
violation signified by a "Y" for data element Cl 131.
2.4.7.4 GWat least 10,000 People
Cross-reference to Stage 1 DBPR Implementation Guidance:
Section II, pages 4 & 13
Section IV-D, page 21
Appendix D, Attachment 4
Cross-reference to Rule:
40CFR141.132(b)
Please see Tables 2-75 and 2-76
If a groundwater system determined not to be under the direct influence of surface water that serves at
least 10,000 people fails to collect and report the necessary one sample per plant per quarter for HAAS
and TTHM, the failure results in an M&R violation for the quarter in which the sample was not taken.
The appropriate data elements and DTP transactions would be as shown in Exhibit 2-20, except the
Begin and End Dates of Compliance Period should be the begin and end dates of the quarter in which the
violation took place. The M&R violation is a Major violation if the sample missed results in less than
90% of the samples required being collected in that quarter. A Major M&R violation is signified by a
"Y" for data element Cl 131.
2.4.7.5 GW< 10,000 People
Cross-reference to Stage 1 DBPR Implementation Guidance:
Section II, pages 4 and 13
Section IV-D, page 21
Appendix D, Attachment 5
Cross-reference to Rule:
40CFR141.132(b)
Please see Tables 2-75 and 2-76
If a groundwater system, determined not to be under the direct influence of surface water, that serves less
than 10,000 people fails to collect and report the necessary one sample per plant per year for HAAS and
TTHM, the failure results in an M&R violation for the calendar year in which no sample was collected.
Stage 1 DBPR Reporting Guidance Page 2-117 January 2003
-------
The appropriate data elements and DTP transactions would be as shown in Exhibit 2-20, except the
Compliance Period Begin and End Dates should be the beginning and end of the calendar year in which
the violation took place. The M&R violation is a Major violation signified by a "Y" for data element
C1131.
2.4.8 Type 27/2920: Source and Finished Water TOC / Source Water Monitoring Alkalinity
Cross-reference to Stage 1DBPR Implementation Guidance:
Section II, pages 4 & 11
Section IV-D, page 28
Appendix D, Attachment 8, page 53
Cross-reference to Rule:
40CFR141.132(d)
Table 2-81. Paired TOC and Alkalinity Monitoring and Reporting Violation
Violation Code
27
Contaminant
Code
2920
Violation Description
A failure to collect source and finished water TOC samples and
alkalinity sample
Example System Description - System QQ
System QQ is a Subpart H system serving 18,000 people that uses a GWUDI source and a single
conventional treatment plant. Chlorine is used for primary and secondary disinfection. The Stage 1
DBPR includes a requirement to collect and analyze a source water sample for TOC and alkalinity and a
finished water TOC sample once per month (at each treatment plant). The requirements of the Stage 1
DBPR are effective for system QQ, since it serves 10,000 or more people, on January 1, 2002.
System QQ Summary
Population Served: 18,000
Source: Groundwater under the direct influence
Treatment: Conventional filtration, chlorine disinfection
Example #42 - M&R Paired TOC/Finished Alkalinity
Table 2-82 summarizes System QQ's monitoring results for the 1st quarter of 2002. On April 1, 2002,
System QQ's operator reviewed the Paired TOC and Alkalinity data he has collected in 2002.
January 2003 Page 2-118 Stage 1 DBPR Reporting Guidance
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Table 2-82. System QQ 2002 TOC and Alkalinity (mg/L)
Parameter
TOC
Source
TOC
Finished
Alkalinity
Source
TOC %
Removal
TOCTT
Removal
JAN
5.9
2.0
105
35%
65%
FEE
No
Sample
No
Sample
No
Sample
-
MAR APR
4.8
2.0
100
35%
65%
MAY JUN JUL AUG SEPT OCX
NOV DEC RAA
Example #42 Decision
System QQ failed to collect the required routine monthly TOC/Alkalinity samples in February 2002.
This results in a monitoring and reporting violation for the 1st quarter of 2002.
Public Notice Requirement
System QQ must provide Tier 3 public notice of this M&R violation according to the requirements of 40
CFR141.201.
System Reporting Requirement
System QQ must routinely report the information summarized in Table 2-53 to the Primacy Agency.
Primacy Agency to SDWIS/FED Reporting
All failures to collect source and finished water TOC and source water alkalinity, regardless of how
many failures occur in a quarter are reported to SDWIS using the data elements and DTP transactions
shown in Exhibit 2-21. The Compliance Period Begin Date and Compliance Period End Date should be
the beginning and end dates of the quarter in which the violation was defined
The appropriate SDWIS/FED TOC and Alkalinity M&R violation data elements and individual DTP
transactions are listed below in Exhibit 2.21.
Stage 1 DBPR Reporting Guidance
Page 2-119
January 2003
-------
Data Elements:
Number Name
Value or Comment
C101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C1103 Contaminant Code 2920
C 1 1 05 Violation Type Code 27
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date 3 months later than C1107
C 1 1 3 1 Maj or Violation Flag Y
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234579
GA1234579
GA1234579
GA1234579
GA1234579
12-18
0200001
0200001
0200001
0200001
0200001
19-25
26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1131
32-71
2920
27
20020101
20020331
Y
72-74
75-80
Exhibit 2.21 TOC/Alkalinity M&R Violations Data Element Table and Individual
DTF Transactions
January 2003
Page 2-120
Stage 1 DBPR Reporting Guidance
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Section 3
General SDWIS Reporting
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General SDWIS Reporting
3.1 Federally Reported Violations
Under SDWIS/FED reporting, Primacy Agencies only report when violations occur. In the interest of
reducing the reporting burden on Primacy Agencies, EPA has limited the number and type of violations
to be reported to SDWIS/FED. However, PWSs must still keep records and report all required
information to the Primacy Agency. Any violation of the rule, whether included in Table 2. la or not, is a
basis for a Primacy Agency or federal enforcement action.
Table II-2, from the Stage 1 DBPR Implementation Guidance (EPA 816-R-01-012), Part II, page II-5,
contains the federally reportable violations for the Stage 1 DBPR in detail. These violations are listed by
contaminant and violation type. The table includes the SDWIS/FED reporting codes, the regulatory
citation, system type affected, a detailed description of the violation, and the initial compliance date.
This table will contribute to a user's understanding of those violations listed in SDWIS. Tables 2.la and
2.1b in Section 2 of this document pro vide rule specific reporting information. (Please note that in the
Stage 1 DBPR Implementation Guidance (EPA 816-R-01-012) dated June 2001, Table II-2 does not
include violation type 13 and the 27/1008 violation is still included under the 90% Major/Minor
structure.)
SDWIS/FED Reporting
The SDWIS/FED reporting requirements apply to systems of all types and sizes. Although the method of
violation determination may differ between systems, a particular violation code will define the same type
of violation at all systems.
SDWIS/FED Data Transfer File (DTP) Format
Data are reported to SDWIS/FED via a formatted Data Transfer File (DTP). Exhibit 3.1 depicts the
format of a DTP transaction.
Stage 1 DBPR Reporting Guidance Page 3 - 1 January 2003
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1-2
Form ID
3-11
Quail
12-18
Qual2
19-25
QualS
26
DIM
Code
27-31
DE Number
32-71
Data Value
72-74
Blank
75-80
Batch
Sequence
Number
Form ID
Qualifier 1
Qualifier 2
Qualifier 3
DIM Code
DE (Data Element)
Number
Data Value
An identification number that allows input of certain types of data.
The Public Water System Identifier (PWS-ID) of the Water System to
be inserted, modified, or deleted.
Contains an ID that further defines what record is to be inserted,
modified, or deleted. Qualifier 2 contains the SE ID when reporting
facilities and treatments, the violation ID when reporting violations, and
the enforcement ID when reporting enforcements.
Contains an ID that further defines what record is to be inserted,
modified, or deleted. Qualifier 3 contains the treatment ID when
reporting treatments.
D= Delete
I = Insert
M = Modify
The DTP data element number (e.g., C0483, C1105) identifying a
specific element to be inserted, modified, or deleted.
The data value associated with the data element number.
Batch Sequence Number The number assigned to the group of data being submitted. Used to
sequence processing against the database, if required.
Exhibit 3.1 DTF and Transaction Format
January 2003
Page 3 - 2
Stage 1 DBPR Reporting Guidance
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Section 4
Additional Sources of
Information
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Additional Sources for Technical Information on the Stage 1 DBPR
SDWIS/FED Documents
SDWIS/FED Data Entry Instructions
This document provides details for the creation of all parts of DTP transactions
SDWIS/FED Online Data Dictionary
This application provides details on every table and field contained in SDWIS/FED, including
definitions, permitted values, names, and editing requirements.
Technical Information Available on the Stage 1 DBPR
A series of guidance manuals support the Stage 1 DBPR. The manuals will aid EPA, Primacy Agency,
and affected PWSs in implementing this rule and will help ensure that implementation among these
groups is consistent. Summaries of the manuals and information on how to obtain them are provided
below.
Implementation Guidance for the Stage 1 Disinfectants/Disinfection Byproducts Rule
(EPA 816-R-01-012)
Objective: To provide guidance to EPA Regions and States exercising primary enforcement
responsibility under the Safe Drinking Water Act (SDWA) concerning how EPA
interprets the Stage 1 DBPR under SDWA. It also provides guidance to the public and
the regulated community on how EPA intends to exercise its discretion in implementing
the statute and regulations. The guidance is designed to implement national policy
regarding the Stage 1 DBPR.
Contents: The guidance manual includes four (4) sections, discussing Rule Requirements, SDWIS
Reporting, and SNC, State Primacy Revision Applications and other supporting
information. It includes six (6) appendices, including a Primacy Revision Crosswalk,
Sample Primacy Revision Application Extension Agreement, guidance on adult law
issues, a Stage 1 plain English summary, a copy of the Stage 1 DBPR language and
example Stage 1 DBPR monitoring forms.
Alternative Disinfectants and Oxidants Guidance Manual (EPA 815-R-99-014)
Objective: To provide technical data and engineering information on disinfectants and oxidants that
are not as commonly used as chlorine so that systems can evaluate their options for
developing disinfection schemes to control water quality problems such as zebra mussels
and Asiatic clams, and oxidation to control water quality problems associated with iron
and manganese.
Contents: The manual discusses six disinfectants and oxidants: ozone, chlorine dioxide, potassium
permanganate, chloramines, ozone/hydrogen peroxide combinations, and ultraviolet light.
A decision tree is provided to assist in evaluating which disinfectant, or disinfectants, is
most appropriate given certain site-specific conditions (e.g., water quality conditions,
existing treatment, and operator skill). The manual also contains a summary of existing
alternative disinfectants used in the U.S. and cost estimates for the use of alternative
disinfectants.
Stage 1 DBPR Reporting Guidance
Page 4-1
January 2003
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MDBP Simultaneous Compliance Guidance Manual (EPA 815-R-99-015)
Objective: To assist PWSs with complying simultaneously with various drinking water regulations
(e.g., Stage 1 DBPR, IESWTR, Lead and Copper Rule, and the Total Coliform Rule).
The manual discusses operational problems systems may encounter when implementing
these rules.
Contents: The manual provides detailed information on the requirements in the Stage 1 DBPR and
the IESWTR.
Enhanced Coagulation and Enhanced Precipitative Softening Guidance Manual
(EPA 815-R-99-012)
Objective: To assist utilities in implementing, monitoring, and complying with the treatment
technique requirements in the final Stage 1 DBPR and to provide guidance to Primacy
Agency staff responsible for implementing the treatment requirements.
Contents: The manual provides detailed information on the total organic carbon (TOC) removal
requirement, explains how to set an alternative TOC removal percentage under the Step 2
procedure, details monitoring, reporting, and compliance requirements, and discusses
strategies that can be employed to mitigate the potential secondary effects on plant
performance due to implementation of the treatment technique.
Other Information Sources
Public Notice Handbook (EPA 816-R-00-010)
Objective: To assist water systems in implementing the revised public notification regulation
published in the Federal Register on May 4, 2000, (65 FR 25981). The handbook's
purpose is to explain EPA's revised public notification rule and provide specific examples
of public notices.
Contents: The manual provides a summary of the public notice requirements, and provides detailed
examples and explanations of Tier 1, 2 and 3 notice. Templates are provided for specific
public notification releases, and to address the special needs of noncommunity systems.
Final Implementation Guidance for the Public Notification Rule (EPA 816-R-01-010)
Objective: To assist States in applying for primacy revision for the Public Notification Rule.
Contents: Information on the primacy revision process - the procedures, timeframes, and content for
submission of a State primacy revision application - are outlined in the document. The
document also includes the Draft Final Version of SDWLS Reporting in the document's
Appendix C.
January 2003
Page 4 - 2
Stage 1 DBPR Reporting Guidance
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