,\ ,. PRIMACY AGENCY 0 DATA ENTRY INSTRUCTIONS, WITH EXAMPLES, FOR STAGE 1 DISINFECTANTS AND DISINFECTION BYPRODUCTS RULE (STAGE 1 DBPR) ------- Office of Water (4606M) EPA816-R-02-012 www.epa.gov/safewater January 2003 Printed on Recycled Paper ------- 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. ------- This page intentionally left blank ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 Stage 1 DBPR Reporting Guidance v January 2003 ------- This page intentionally left blank January 2003 vi Stage 1 DBPR Reporting Guidance ------- 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 ------- 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 ------- 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 January 2003 ------- This page intentionally left blank January 2003 x Stage 1 DBPR Reporting Guidance ------- Section 1 Introduction ------- This page intentionally left blank ------- 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 ------- 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 Page 1 - 2 Stage 1 DBPR Reporting Guidance ------- 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. Stage 1 DBPR Reporting Guidance Page 1 - 3 January 2003 ------- This page intentionally left blank January 2003 Page 1 - 4 Stage 1 DBPR Reporting Guidance ------- Section 2 Violation Reporting ------- This page intentionally left blank ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- Section 3 General SDWIS Reporting ------- This page intentionally left blank ------- 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 ------- 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 ------- Section 4 Additional Sources of Information ------- This page intentionally left blank ------- 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 ------- 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 ------- |