The U.S. Environmental Protection Agency (EPA) is targeting publication of the final Stage 2 Disinfectants and Disinfection Byproducts Rule (Stage 2 DBPR) and the Long-Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) for December 15, 2005. Both rules have been delayed in the past, but the EPA is committed to meeting this deadline by a legal agreement.
More Stage 2 Articles |
» | Learning About the New Rules on the Web - Dec. 2005 [ more ] |
» | Implementing the Stage 2 Rules: Prepare for Staff Time and Budget Impacts - Aug. 2005 [ more ] |
For the Stage 2 DBP Rule, systems serving more than 100,000 people will be required to submit Initial Distribution System Evaluation (IDSE) plans within six months of the final rule publication. The plan will provide details on how the utility is to complete the IDSE using either a Standard Monitoring Plan (SMP) approach or a System Specific Study (SSS). The regulatory agency (State and/or EPA) will have 12 months to review and approve the plan. Utilities will then have 12 months to complete the study, including required sampling, and three months to submit the final IDSE Report. Systems serving 50,000 to 100,000 people will submit IDSE plans 12 months after the rule is finalized and then follow a similar schedule. Deadlines for smaller systems will be staggered chronologically and apply to systems serving more than 500 people.
In November, at the AWWA Water Quality Technology Conference, the EPA distributed a flyer entitled "Five Recommended Steps to Prepare for the IDSE." While there is not much detail included in this advice, the EPA presents suggestions that may be helpful to some utilities in approaching the Stage 2 DBP Rule and IDSE requirements. The EPA recommends the following:
1. Make sure your utility contact information is correct.Systems serving more than 50,000 people should have received a letter from the EPA regarding the Stage 2 DBP Rule. The contact information should be corrected by calling your state.
2. Coordinate plans for the IDSE with other utilities in your combined distribution system.
3. Contact the laboratory you use for TTHM and HAA5 analyses to let them know you will be sending more samples and give them an idea of the schedule. (Note: The EPA has not yet released the actual number of IDSE samples each utility must take.)
4. Gather data that may be useful in selecting your IDSE option or deciding where to monitor for the IDSE including:
a. Distribution system maps
b. Locations of system components (entry points, tanks, pump stations)
c. Disinfectant residual data
d. THM and HAA5 data
e. HPC data
f. Distribution system operational data (tank levels, pump run times, SCADA)
g. Population density, location of large users
h. Hydraulic model, if available
5. When the rule is final, use the EPA’s Web-based IDSE tool to figure out which option to use and to work through the IDSE plan development process.The tool will be located on the EPA Web site after the rule is final at http://www.epa.gov/safewater/stage2/index.html.
Additional suggestions for Stage 2 DBPR preparation have been made by AWWA in a regulatory alert to members, including:
Determine your schedule for the IDSE. If you are in a combined distribution system, you are on the schedule of the largest system in your combined system.
Evaluate your existing data to determine whether you may be eligible for a waiver from the IDSE (all routine compliance monitoring results are below 40 ug/L for TTHM and 30 ug/L for HAA5 for two years).
Decide whether to use the SMP or SSS approach to the IDSE and budget for the process.
Suggestions for preparing your utility to meet both the Stage 2 DBPR and the LT2ESWTR have been the subject of articles in the SDWA Newsletters from April, July and November 2004, and February and August 2005. Copies of these newsletters are at http://goto.hdrinc.com/sdwa.
For more information contact Sarah Clark in our Denver, Colorado, office at 303-764-1560.