| TO: |
AWWA
Leadership
All Utilities |
| FROM: |
Jack
Hoffbuhr |
| DATE: |
October 24, 2000 |
| |
| Who: |
AWWA |
| What: |
Support of
Negotiated Rulemaking Framework for Stage 2 M/DBP Rule |
| When: |
October 24, 2000 |
AWWA
has agreed to support the rulemaking framework negotiated by the
stakeholder group convened by the U.S. Environmental Protection Agency
(USEPA) for Stage 2 of the Microbial/Disinfectant By-Product rule (M/DBP).
While AWWA does not perceive the final agreement to be perfect, the
Association does believe it is a sensible, workable way to ensure the
regulation improves public health protection taking prudent actions, based
on best information available. The proposed rule USEPA will issue next
year will closely resemble this negotiated agreement, so AWWA utility
members are strongly encouraged to acquaint themselves with it. . Those
members with internet access can view the agreement on the AWWA web site
(http://www.awwa.org/govtaff/govnew.htm). AWWA members can obtain copies
of the agreement by calling Government Affairs Office at 202-628-8303.
AWWA also plans to issue a joint public statement with the other
drinking water stakeholders involved in the negotiations about the
agreement later this week. AWWA will continue to update its members on
important milestones of the rulemaking as work on the Stage 2 rule
continues.
Background:
For 18 months, AWWA has been involved in negotiations under the
Federal Advisory Committee Act (FACA) with stakeholders from the drinking
water profession, environmental community, health profession and USEPA to
produce a framework on which Stage 2 of the M/DBP regulation will be
based. Other drinking water stakeholders involved in the FACA negotiations
were the Association of Metropolitan Water Agencies, the National
Association of Water Companies and the National Rural Water Association,
and a representative for unfiltered systems, all of which have indicated
they intend to support the agreement. Key tenets of the agreement are
listed below, however, this brief synopsis should not serve as a utility
member's full consideration of this rule. The Stage 2 rule is very
specific and has far-reaching implications for each utility based on their
specific situation. As such, AWWA strongly encourages each of its utility
members to obtain a copy of the agreement through the means suggested
above and closely analyze the rule's ramifications in their entirety.
DBP's
The agreement dictates how Total Trihalomethane (TTHM) and
Haloacetic Acid (HAA5) levels will be monitored and reduced under the
Stage 2 Disinfection Byproduct Rule. Compliance will be based upon a
Locational Running Annual Average (LRAA) at a number of different points
at the water system, which vary based on the size, source water and
secondary disinfectant employed
The new DBP regulations will be implemented in phases.
- Three years after the rule is promulgated, all systems will be
required to comply with the 120 microgram per liter (ug/L) TTHM level
and 100ug/L HAA5 standard on a LRAA at sites specified under the Stage 1
Disinfectant /Disinfection Byproducts Rule.
- Systems will also continue to have to comply with the 80 ug/L TTHM
/60 ug/L HAA5 requirements for a running annual average as stipulated in
the Stage1 DBPR.
- Six years after promulgation, all systems will be required to lower
the LRAA levels to 80 ug/L TTHM /60 ug/L HAA5 based on sampling at
revised compliance sites determined under the Initial Distribution
System Evaluation (IDSE) process.
The location of sampling sites to be identified in the IDSE process
are specific to the source water, disinfection agent and size of each
system, and the requirements for each type of system are laid out fully in
the agreement. Likewise, the rule's Long Term monitoring requirements will
be specific to type of system as well. The requirements for each can be
found in section 3.1a and 3.1b of the agreement. AWWA strongly encourages
its members to review these sections of the agreement to understand
exactly what new monitoring will be required of them.
Cryptosporidium
Under the Long-Term 2 Enhanced Surface Water Treatment Rule
Cryptosporidium new monitoring and treatment requirements come into play
Monitoring:
Cryptosporidium and E.coli concentrations, along with turbidity
levels, will be monitored using EPA Method 1622/23 in samples no smaller
than 10 liters for 2 years.
The resulting average Cryptosporidium occurrence based on the
highest levels observed in 12 consecutive months will be used to assign
each utility to an "action bin" which will determine what Cryptosporidium
reduction actions the utility will be required to perform. The range of
actions is as follows:
Systems with Cryptosporidium levels below .075/L will not be required
to take action.
Systems with Cryptosporidium levels between .075/L and 1.0/L will have
to acheive 1-log removal.
Systems with Cryptosporidium levels between 1.0/L and 3.0/L will have
to achieve 2-log removal.
Systems with Cryptosporidium levels of 3.0/L and above will have to
achieve 2.5-log removal.
The rule also stipulates that systems with higher levels of
Cryptosporidium in their source water must achieve the applicable rate of
removal at least in part by implementing specific disinfection or
treatment improvements. Thus, utilities should review the "Bin
Requirements Table" on page 14 of the agreement to ascertain exactly how
they will be expected to reduce Cryptosporidium concentrations under the
rule.
Treatment:
Utility members should also review page 16 of the agreement to
familiarize themselves with the "Microbial Toolbox". The Toolbox
encompasses a number of different microbial reduction approaches available
to systems in trying to comply with the Stage 2 Long-Term 2 Enhanced
Surface Water Treatment Rule including:
- Watershed control programs to reduce oocyst concentration and viable
oocyst concentrations.
- Intake relocation
- Management of oocyst capture, timing of withdrawal and level of
withdrawal in water column
- Off-stream raw water storage with detention
- The addition of slow sand filters, membranes or cartridge filters
- Use of alternative disinfectants: chlorine dioxide, ozone and UV
- Peer Review or Similar Demonstration/Validation of System
Performance
AWWA strongly supports the inclusion of the Toolbox in the rule
because it reflects the reality that the best approach to reducing
Cryptosporidium concentrations will vary from system to system. However,
the agreement leaves no doubt that many systems will have to implement
some combination of strategies available in the Toolbox. Utilities are
strongly encouraged to evaluate their options in regard to the Toolbox to
determine what approaches -or combinations of approaches-will best suit
their needs for Cryptosporidium reduction under the rule.
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