State of AlaskaImplementation of
MBDP Rules
Carrie BohanEnvironmental Program
SpecialistADEC DW Program
Rule promulgated by US EPA December 16, 1998 Adopted by the State of Alaska on September 28,
2001 Effective for surface water systems or GWUDISW
systems (Subpart H) serving 10,000+ on January 1, 2002
Effective for surface water or GWUDISW systems serving <10,000, and all ground water systems on January 1, 2004
CWS, NTNCWS and TNCWS using chlorine dioxide
Stage 1 D/DBRBasic Requirements
Basic Requirements MCLs and monitoring requirements for TTHMs, HAA5s,
Bromate, and Chlorite
MRDL for Chlorine, Chloramines and Chlorine Dioxide
Treatment technique for enhanced coagulation/softening
to improve precursor removal for conventional filtration
plants
Stage 1 D/DBRBasic Requirements
Monitoring Requirements
Stage 1 D/DBR
Coverage Monitoring Frequency
Compliance
TTHM/HAA5 Surface and GWUDISW serving > 10,000
4/plant/quarter Running Annual Average
Surface and GWUDISW serving 500 – 9,999
1/plant/quarter Running Annual Average
Surface and GWUSIDW serving < 500
1/plant/year in month of warmest water temperature
Running Annual Average
Ground water serving > 10,000 1/plant/quarter Running Annual Average
Ground water serving 10,000 1/plant/year in month of warmest water temperature
Running Annual Average
Bromate Ozone plants Monthly Running Annual Average
Chlorite Chlorine dioxide plants Daily at EP to DS, Monthly in DS Daily
Chlorine Dioxide
Chlorine dioxide plants Daily at EP to DS Daily
Chlorine/Chloramines
All Systems Same location and frequency as TCR sampling
Running Annual Average
DBP Precursors
Conventional filtration plants Monthly for TOC and Alkalinity Running Annual Average
Basic Requirements
Compliance Determination If monitoring annually, results of one annual sample
If exceed the MCL, must go to quarterly sampling
If monitoring quarterly, average of past four quarters
(running annual average)
Monthly samples are averaged quarterly, compliance is
based on running annual average of quarterly averages
Stage 1 D/DBRCompliance Determination
Violation Types MCL Violations
TTHMs, HAA5s, Bromate, Chlorite MRDL Violations
Chlorine, Chloramines Treatment Technique Violations
Not meeting Precursor Removal Monitoring and Reporting Violations
Not collecting any individual sample Most commonly distribution system chlorine residual
Not submitting reporting forms in a timely fashion
Public Notification Violations Failure to conduct PN as required for violations
Acute – 24 hours, MCL/TT – 30 days, M/R – 1 year
Stage 1 D/DBRCompliance Determination
Reporting Forms www.dec.state.ak.us/eh/dw/publications/forms.html
Quarterly TTHM/HAA5 RAA reports
Quarterly Bromate/Bromide Reports
Quarterly MRDL reports
Quarterly Enhanced Coagulation Reports
Stage 1 D/DBRCompliance Determination
Significant Non-Complier List (SNC) Monthly Monitoring (Chlorine residual, MRDL)
A combination of 4 or more MCL or MRDL violations in any 12
consecutive months
A combination of 6 or more MCL, MRDL and Major
Monitoring/Reporting violations in any 12 consecutive months
A combination of 10 or more MCL, MRDL, Major and Minor M/R
violations in any 12 consecutive months
Stage 1 D/DBRCompliance Determination
Significant Non-Complier List (SNC) Quarterly Monitoring (TTHM/HAA5s, Bromate)
A combination of 2 or more MCL, MRDL, Treatment Technique,
and Major M/R violations in any 12 consecutive months
A combination of 3 or more MCL, MRDL, Treatment Technique,
and Major or Minor M/R violations in any 12 consecutive months
Annual or Less Frequent Monitoring Failing to collect or report all required samples
If exceed the MCL, go to quarterly monitoring, no violation
Also…. Failure to obtain State approval before making significant
changes to existing treatment process
Stage 1 D/DBRCompliance Determination
Significant Non-Complier List (SNC) All SNC violations for Stage 1 take 12 months to Return
to Compliance, or until the end of the quarterly violation Example...
Stage 1 D/DBRCompliance Determination
ExampleSystem A
Surface water system serving 425August 2007 Annual samples
TTHM 82 ug/L HAA5 90 ug/L
No ViolationMust begin quarterly samples
Stage 1 D/DBRCompliance Determination
TTHM HAA5
Q4 2007
Q1 2008
Q2 2008
Q3 2008
78 ug/L
83 ug/L
67 ug/L 69 ug/L
78 ug/L88 ug/L
101 ug/L
93 ug/L
RAA 79 ug/L 85.3 ug/L
ExampleSystem AQ3 2008
System receives an MCL violation for Q3 2008Must continue quarterly sampling
Stage 1 D/DBRCompliance Determination
TTHM HAA5
Q4 2007
Q1 2008
Q2 2008
Q3 2008
78 ug/L
83 ug/L
67 ug/L 69 ug/L
78 ug/L88 ug/L
101 ug/L
93 ug/L
RAA 79 ug/L 85.3 ug/L
ExampleSystem AQ4 2008
Stage 1 D/DBRCompliance Determination
TTHM HAA5
Q1 2008
Q2 2008
Q3 2008
Q4 2008
83 ug/L
67 ug/L
88 ug/L 78 ug/L
86 ug/L72 ug/L
69 ug/L
101 ug/L
RAA 77.5 ug/L 83.5 ug/L
Second consecutive quarterly MCL violation for HAA5s
Qualifies for SNC status
Stage 1 D/DBRCompliance Determination
TTHM HAA5
Q4 2008
Q1 2009
Q2 2009
Q3 2009
72 ug/L
64 ug/L
68 ug/L 51 ug/L
43 ug/L62 ug/L
57 ug/L
86 ug/L
RAA 66.5 ug/L 59.3 ug/L
Can take up to 1 year of lower results to bring the RAA below the MCL.
Receives quarterly MCL violations until RAA is below the MCL.
TTHM HAA5
Q1 2008
Q2 2008
Q3 2008
Q4 2008
83 ug/L
67 ug/L
88 ug/L 78 ug/L
86 ug/L72 ug/L
69 ug/L
101 ug/L
RAA 77.5 ug/L 83.5 ug/L
ExampleSystem AQ4 2008
Q3 2009
Example
System A
Stage 1 D/DBRCompliance Determination
TTHM HAA5
Q3 2009
Q4 2009
Q1 2010
Q2 2010
62 ug/L
59 ug/L
61 ug/L 51 ug/L
47 ug/L66 ug/L
46 ug/L
43 ug/L
RAA 62 ug/L 46.8 ug/L
Once RAA is below the MCL, will take one year to come off the SNC List.
TTHM HAA5
Q4 2008
Q1 2009
Q2 2009
Q3 2009
72 ug/L
64 ug/L
68 ug/L 51 ug/L
43 ug/L62 ug/L
57 ug/L
86 ug/L
RAA 66.5 ug/L 59.3 ug/L
Q2 2010
Example
System A
Stage 1 D/DBRCompliance Determination
TTHM HAA5
Q3 2009
Q4 2009
Q1 2010
Q2 2010
62 ug/L
59 ug/L
61 ug/L 51 ug/L
47 ug/L66 ug/L
46 ug/L
43 ug/L
RAA 62 ug/L 46.8 ug/L
In this example, it took 2 years from the initial violation to come off the
SNC List.
TTHM HAA5
Q4 2007
Q1 2008
Q2 2008
Q3 2008
78 ug/L
83 ug/L
67 ug/L 69 ug/L
78 ug/L88 ug/L
101 ug/L
93 ug/L
RAA 79 ug/L 85.3 ug/L
Stage 2 D/DBRCompliance Determination
Rule promulgated January 4, 2006
State has 2 years to adopt January 4, 2008
Have applied for a 2 year extension January 4, 2010
No early implementation by the State
Until Alaska adopts the rule, systems will work directly with EPA
Stage 2 D/DBRCompliance Determination
Assuming the State adopts in early 2010 All systems will submit 40/30 certifications, VSS waiver
requests, Standard Monitoring or System Specific Study plans to EPA
Schedule 1 and 2 systems will conduct Standard Monitoring or System Specific Study sampling and submit the IDSE report to EPA
Schedule 3 and 4 systems will submit IDSE report to ADEC
Violations Types Monitoring/Reporting Violations
Failure to submit Monitoring Plan on time
Failure to monitor
MCL violation
LRAA exceeds the MCL
SNC Lists EPA has not yet determined SNC definitions
Stage 2 D/DBRCompliance Determination
Promulgated December 16, 1998 and January 14,
2005, respectively Lowered turbidity treatment technique standards
Requires individual filter effluent turbidity monitoring Follow up activities for exceeding certain triggers
Filter Profile, Filter Self Assessment, Comprehensive Performance
Evaluation
Filtered systems must meet 2-log Crypto removal
Increased sanitary survey frequency, no new uncovered
finished water storage tanks
IESWTR/LT1Basic Requirements
Promulgated December 16, 1998 and January 14,
2002, respectively Lowered turbidity treatment technique standards
Requires continuous individual filter effluent turbidity
monitoring Follow up activities for exceeding certain triggers
Filter Profile, Filter Self Assessment, Comprehensive Performance
Evaluation
Filtered systems must meet 2-log Crypto removal
Increased sanitary survey frequency, no new uncovered
finished water storage tanks
IESWTR/LT1Basic Requirements
Types of Violations Monitoring/Reporting
Failure to conduct daily entry point chlorine residual monitoring**
Failure to conduct distribution system chlorine residual monitoring at the same time and location as monthly bacti**
Failure to conduct daily treated water turbidity monitoring** Failure to conduct continuous individual filter effluent
monitoring Failure to conduct triggered activity from IFE readings Failure to submit monthly reports on time Failure to conduct Disinfection Profile & Benchmark if
required Failure to report turbidity MCL violation within 24 hours
IESWTR/LT1Compliance Determination
** SWTR violations
Types of Violations Treatment Technique Violations
Failure to meet 2-log removal of Cryptosporidium
Failure to meet turbidity standards Alternative filtration – 1.49 NTUs 95% of samples
Direct/Conventional filtration – 0.3 NTUs in 95% of samples
MCL Violations Exceeding the turbidity MCL
Alternate filtration – 5 NTUs
Direct/Conventional filtration – 1.49 NTUs
Public Notification Violations Failure to conduct PN as required for violations
IESWTR/LT1Compliance Determination
Reporting forms http://www.dec.state.ak.us/eh/dw/publications/forms.html
4 Versions Direct/Conventional systems with 3 or more filters
Continuous IFE turbidity monitoring
Direct/Conventional systems with 1 or 2 filters Continuous CFE turbidity monitoring in lieu of continuous IFE
monitoring
Alternative/slow sand systems
Alternative/slow sand systems with reduced monitoring Serve less than 500, reduced to one chlorine residual reading per
day
IESWTR/LT1Compliance Determination
Significant Non-Complier List (SNC) Unfiltered Systems
Systems that fail avoidance criteria and do not install filtration within 18 months
3 or more Major M/R violations in any 12 consecutive months
5 or more Major and/or Minor M/R violations in any 12 consecutive months
Filtered Systems 4 or more TT violations in any 12 consecutive months 6 or more TT and/or Major M/R violations in any in 12
consecutive months 10 or more TT, Major and/or Minor M/R violations in any 12
consecutive months All SNC violations for SWTRs take 6 months to Return to
Compliance
IESWTR/LT1Compliance Determination
Promulgated January 5, 2006
State has 2 years to adopt January 5, 2008
Have applied for a 2 year extension January 5, 2010
No early implementation by the State All plan reviews for new systems or system improvements are
held to LT2 standards
Until Alaska adopts the rule, systems will work directly
with EPA
LT2Basic Information
Assuming the State adopts in early 2010 All systems will submit to EPA
Samples schedules for initial source water monitoring Results of initial source water monitoring Notification of uncovered finished water storage tanks
Schedule 1 and 2 systems will submit Bin Classification or mean Crypto sample results to EPA
Schedule 3 system will submit Bin Classification or mean Crypto sample results to ADEC
Schedule 4 systems required to conduct Crypto monitoring will submit sample schedules to ADEC
LT2Rule Adoption
Violations Monitoring/Reporting Violations
Failure to submit monitoring plan Failure to conduct e.coli monitoring Failure to collect a sample within the 5-day period around a
scheduled date (unless extenuating)
LT2Compliance Determination
Violations Treatment Technique Violations
Failure to collect Crypto samples to determine bin classification
Failure to provide required treatment by the established compliance date
Failure to meet monthly Crypto inactivation requirements Ozone or Chlorine dioxide – more than 1 day per month UV – more than 5% of water delivered
Failure to meet IFE performance criteria for tool box credit
SNC List EPA has not yet determined SNC definitions
LT2Compliance Determination
Reporting Forms New reporting forms are in the works for LT2
Membrane filtration Direct and indirect integrity testing requirements
UV Calculated dose, set point approach
Ozone
LT2Compliance Determination
EPA’s MDBP Website http://www.epa.gov/safewater/mdbp/mdbp.html Quick Reference Guides and Fact Sheets broken
down by schedule number Source Water Monitoring Guide for LT2 UV and Membranes Guidance Manuals for LT2 IDSE Guidance Manual Simultaneous Compliance Guide for LT2 and
Stage 2 Training on using EPA’s Data Collection and
Tracking System online
More Information