long term 2 (lt2) surface water treatment rule...crypto level 19 system a system b source water...

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Long Term 2 (LT2) Surface Water

Treatment Rule

Round 2: What you need to know

Long Term 2 Enhanced Surface Water

Treatment Rule – Presentation Outline

Introduction of the Rule - Why Cryptosporidium

Federal Requirements

Sampling

Reporting

Analysis and Round One Experience – Laboratory

Questions

Round One Experience – Regulators and Utilities

Round Two – Group Discussion

2

LT2 - Chronology

• SWTR (1989)

• SDWA Amendments (1996)

• DBP1 and IESWTR (1998)

• DBP2 and LT2ESWTR (2006)

• DBP3 and rTCR (Future)

LT2 Purpose = to reduce pathogen (GI) illness

Introduction of the Rule

History:

Disinfection of drinking water is one of the major

public health advances in the 20th century.

100 years ago, typhoid and cholera epidemics were

reduced by disinfection.

In the past 15 years, we found specific microbial

pathogens, such as Cryptosporidium, which can

cause illness, and are highly resistant to traditional

disinfection practices.

Disinfectants themselves can react with naturally-

occurring materials in the water to form byproducts,

which may pose additional health risks.

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Introduction of the Rule (cont)

1996 SDWA amendments

• Require EPA to develop rules to balance the risks between

microbial pathogens and disinfection byproducts (DBPs)

• Stage 1 Disinfectants and Disinfection Byproducts Rule and

Interim Enhanced Surface Water Treatment Rule (promulgated

in December 1998) were the first phase in a rulemaking

strategy.

LT2 and the Stage 2 DBP Rule are the second phase of

rules required by Congress.

• Strengthen protection against microbial contaminants,

especially Cryptosporidium, and at the same time, reduce

potential health risks of DBPs

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Purpose:

To reduce disease incidence associated with

Cryptosporidium and other disease-causing

microorganisms in drinking water

Improve public health protection


Ensures that systems maintain microbial protection as they take

steps to reduce the formation of disinfection byproducts

Addresses the need for filtered public water systems (PWSs)

with higher levels of source water Crypto contamination to

provide additional risk-based treatment for Crypto beyond the

IESWTR or LT1ESWTR requirements

Addresses the need for unfiltered PWSs to provide risk-based

treatment for Crypto to achieve equivalent public health

protection with filtered PWSs

Addresses the need for PWSs with uncovered finished water

storage facilities to take steps to reduce the risk of

contamination of treated water prior to distribution to

consumers

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Why Cryptosporidium?

• Cryptosporidium oocysts are highly resilient and can

survive filtration and disinfection processes

• Resistant to chlorine

• One of the most common causes of waterborne

disease in humans in the U.S.

• Gastrointestinal illness, which may be severe and

potentially fatal to at risk populations

• Methodology also reports Giardia

Why Cryptosporidium (cont)?

9

1993: Cryptosporidium outbreak in Wisconsin

• 400,000+ illnesses

• 50+ deaths

2006: Five states reported outbreaks associated with

recreational water use.

2008: Study on 160 public swimming pools from 2

metro Atlanta counties showed 13 were positive for

one or both of the contaminants (Crypto and/or

Giardia).

Benefits & Costs

Benefits

EPA estimates that full compliance with LT2 will reduce

the incidence of gastrointestinal illness caused by

ingestion of Cryptosporidium by:

• ~ 90,000 – 1.4 million cases per year

• ~ 20 – 300 premature deaths

• Monetized benefits ~$253 million - $1.4 billion

Costs

• EPA estimated range from ~ $92-$133 million.

• Public water systems bear ~99% of costs, states incurring ~1%

• Average annual household cost estimated to be $1.67-$2.59/yr.

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LT2 REQUIREMENTS

11

Federal (USEPA)

Requirements of

the Rule

Federal (USEPA)

LT2 Round One

Report to EPA

USEPA Laboratory Certification

LT2 Round Two

Report to the State

State by State Lab Certification Criteria

• CA = ELAP approval, NV = Federal List

• Or EPA in some States

• Or NELAC in some States

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Applies to all public water systems using

surface water sources or GWUDI sources

Compliance deadlines are based on number

of people served

Divided into four schedules

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Federal (USEPA)

LT2 – Monitoring Requirements

Turbidity (Certified Operator)

E.Coli (State Certified Lab)

Crypto (EPA/State Approval Lab)

• EPA 1622 (Crypto only)

• EPA 1623 (EnviroCheck, EasySeed)

• EPA 1623.1 (AccuSpike, Pellet Wash)

Applicability

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Population Served…> 100,000

(Schedule 1)1

50,000 – 99,999

(Schedule 2)1

10,000 – 49,999

(Schedule 3)1

<10,000

(Schedule 4)1,2

<10,000

(Schedule 4)1,3

Report Sampling Schedules &

Locations For Round II Source

Water MonitoringJanuary 1, 2015 July 1, 2015 July 1, 2016 July 1, 2017 January 1, 2019

Begin Round II Source Water

Monitoring April 1, 2015 October 1, 2015 October 1, 2016 October 1, 2017 April 1, 2019

Report Bin Classification &

Supporting Data from Round II

Monitoring October 1, 2017 April 1, 2018 April 1, 2019 April 1, 2020 October 1, 2022

1 Schedule is defined by the largest system in your combined distribution system2 Applies to filtered system (E. coli only) 3 Applies to unfiltered systems and those filtered systems that exceed the E. coli trigger or do not monitor for E. coli (Crypto)

Requirements of the Rule

Filtered water systems must reduce source water

Crypto levels by 99% (2-log)

Additional treatment is necessary for higher risk

systems

• Filtered systems with high levels of crypto

• All unfiltered water systems

Understanding “log” removal

Percent of Crypto that

is removed or inactivated by

treatment or other measures

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Requirements of the Rule (cont)

‘Log’ Removal Example 1

Both systems provide the same level of Crypto

removal/inactivation, but System B provides

higher quality finished water

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System A (unprotected) System B (pristine)

Source Water 100,000 Crypto oocysts 100 Crypto oocysts

Crypto Reduction 2-log removal /inactivation (99%) 2-log removal /inactivation (99%)

Finished Water 1,000 Crypto oocysts 1 Crypto oocyst



Both systems provide the same public health

protection, but System A must provide a higher

degree of treatment to get there

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System A (unprotected) System B (pristine)

Source Water 100,000 Crypto oocysts 100 Crypto oocysts

Crypto Reduction 5-log removal /inactivation (99.999%) 2-log removal /inactivation (99%)

Finished Water 1 Crypto oocysts 1 Crypto oocyst



System A is able to produce higher quality

finished water than System B, even though

Systems A and B have the same source water

Crypto level

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System A System B

Source Water 1,000 Crypto oocysts 1,000 Crypto oocysts

Crypto Reduction 3-log removal /inactivation (99.9%) 2-log removal /inactivation (99%)

Finished Water 1 Crypto oocysts 10 Crypto oocyst

Bin and Treatment Overview – Filtered

Filtered PWSs will be classified in one of four treatment

categories (“bins”) based on the results of the source water

Crypto monitoring

Bin classification determines the degree of additional Crypto

treatment, if any, the filtered PWS must provide

Occurrence data indicate that most filtered PWSs will be

classified in Bin 1, which carries no additional treatment

requirements

PWSs classified in Bins 2, 3, or 4 must achieve an additional 1.0-

to 2.5-log of treatment (i.e., 90 to 99.7 percent reduction) for

Crypto over and above the 2-log removal currently provided

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Bin and Treatment Overview – Unfiltered

Unfiltered systems’ treatment requirements are based

on the results of their initial source water monitoring:

• Unfiltered systems with a mean Crypto level of 0.01

oocysts/L or less must provide at least 2-log Crypto

inactivation

• Unfiltered systems with a mean Crypto level of greater than

0.01 oocysts/L must provide at least 3-log Crypto

inactivation

• This must be accomplished using a minimum of two

disinfectants

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Bin Classification

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For PWSs that are:With a Cryptosporidium bin

concentration of …

The bin classification

is . . .

*** required to

monitor for

Cryptosporidium

less than 0.075 oocysts/L Bin 1

0.075 oocysts/L or higher, but less than

1.0 oocysts/LBin 2

1.0 oocysts/L or higher, but less than

3.0 oocysts/LBin 3

3.0 oocysts/L or higher Bin 4

* * * serving fewer

than 10,000 people

and NOT required to

monitor for

Cryptosporidium1

NA Bin 1

Calculating Risk Bin Classification

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• If collecting monthly for 2 years

• Bin classification is calculated by averaging each 12 month

period over the 2 years

– (April 2015-March 2016, May 2015-April 2016, etc)

• Highest 12 month average would be used to determine bin

classification

• If collecting twice monthly for 2 years

• Average all 48 samples from the 2 year period


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Example 1: Collecting 1 sample monthly for 2 years. Highest

12 month average would be used to determine bin

classification

Average for April 2015-March 2016 = 6 oocysts/ 123.5 L = 0.048 oocysts/L

Highest Average is Oct. 2015-Sept. 2016 = 10 oocysts/ 124.5L =

0.080 oocysts/L (BIN 2)

Month April

2015

May June July August Sept. Oct. Nov. Dec. Jan.

2016

Feb. March

Oocysts 0 0 1 2 2 0 0 0 0 0 0 1

Volume

filtered

in liters

10 10 10.5 10 11 10 10 10.5 10 10 10.5 11

Month April

2016


2017

Feb. March

Oocysts 0 0 3 3 2 1 0 0 0 0 0 0

Volume

filtered

in liters

10 10.5 11.5 10 10.5 10 10 10.5 10 10 10 10


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Example 2: Collecting twice monthly for 2 years. Average all

48 samples from the 2 year period

Average for all 48 samples = 21 oocysts/ 489 L = 0.043 oocysts/L (Bin 1)

Difference in cost of additional testing versus cost of additional treatment

for Bin 2 classification is significant!

Month April

2015


2016

Feb. March

Oocysts 0/0 0/0 0/1 1/2 2/1 0/0 0/0 0/0 0/0 0/0 0/0 0/1

Volume

filtered

in liters

10/10 10/10 10/10.5 10/10 11/10.5 10/10 10/10 10.5/10 10/10 10/10 10/10.5 11/11

Month April

2016


2017

Feb. March

Oocysts 0/0 0/0 1/3 3/2 2/1 1/0 0/0 0/0 0/0 0/0 0/0 0/0

Volume

filtered

in liters

10/10 10/10.5 10/11.5 10/10 10/10.5 10/10 10/10 10.5/

10.5

10.5/10 10/10 10/10 10/10


Additional Crypto treatment required according to current

Crypto oocyst concentration:

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LT2 REQUIREMENTS - CA/NV

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CA/NV

Requirements of

the Rule


Reporting Results – Lab or System?

• All source water samples taken under the LT2 rule

must be reported to your respective state agency.

• The system or the laboratory may submit the source

water monitoring data to the state agency.

• The system will need to review and approve the source

water monitoring data before it is submitted to the

state.

• The PWS is ultimately responsible for making sure the

lab reports the monitoring data.

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Forms.

• EPA states that systems must report LT2 monitoring to

the state no later than 10 days after the end of the first

month following the month when the samples were

collected (e.g., a system that collects samples in

October 2015 must report that data no later than

December 10, 2015).

• Data must be reported monthly.

NV LT2 reporting – No electronic reporting. Will be

modifying current forms and process to accommodate

LT2.

CA LT2 reporting – Electronic reporting via State Write

On database. Modifying PWS IDs to be consistent with 29

Reporting Components

Cryptosporidium sample:

• PWS ID

• Facility ID

• Sample collection date

• Sample type (field or matrix spike)

• Sample volume filtered (L), to nearest ¼ L

• Was 100% of filtered volume examined, Y/N

• Number of oocysts counted

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Reporting Continued

E. coli samples:

• PWS ID

• Facility ID

• Sample collection date

• Analytical method number

• Method type

• Source type (flowing stream, lake/reservoir, GUDI)

• E. coli/100 mL

• Turbidity

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Reporting Continued

For matrix spike samples, systems must also report

the sample volume spiked and estimated number of

oocysts spiked.

• For samples in which less than 10 L is filtered or less than 100%

of sample volume is examined, systems must also report the

number of filters used and the packed pellet volume.

• For samples in which less than 100% of sample volume is

examined, systems must also report the volume of re-

suspended concentrate and volume of this re-suspension

processed through immunomagnetic separation.

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Sample Plans

• Sampling plans due dates are established by a

system’s schedule.

• Systems serving 100,000 or more sample the earliest

and are required to submit their sampling schedule to

the state by January 1, 2015, with sampling to begin

during the month of April 2015.

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Schedule 1-4

Population

Served

Sampling for SAMPLING PLAN

DUE to CA/NV

SAMPLING

TO BEGIN

1

100,000 or

more served

Cryptosporidium, E. coli,

turbidity-24 months

1-1-2015 4-1-2015

2

50,000 to

99,999 served


turbidity-24 months

7-1-2015 10-1-2015

3

10,000 to

49,999 served


turbidity-24 months

7-1-2016 10-1-2016

4

Less than

10,000 served

E. coli-12 months 7-1-2017 10-1-2017

34

Sampling

Where do I collect my sample?

Systems must submit a description of their sampling

location to the State at the same time as the sampling

schedule is required to be submitted.

Systems must collect source water samples (crypto, E.

Coli and turbidity) prior to any chemical treatment.

Systems that recycle filter backwash water must

collect source samples prior to the point of filter

backwash addition.

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Sampling

Coordinate with your Laboratory

Crypto and E. Coli sample analysis must be performed

at EPA or State approved laboratories

Crypto samples must be sent to a lab certified by ELAP

for LT2 Crypto.

Receipt at lab within (generally) <24 hours (E Coli), <72

hours (Crypto) <20 degrees C, confirm laboratory

hours/days of operation (typically M-Th)

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Sampling

What equipment and instructions provided?

• Field filtering vs 10L Bulk Water Collection

• EnvirochekTM

• Envirochek HV CapsulesTM

• Filta-Max® Filter

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LT2 – Sample Collection

1. Flush (2-3 min) until turb/temp stable

2. Fill Cubitainer and Ship (after flush)

1. Connect Sample Unit without filter

2. Flush (2-3 min) until turb/temp stable

3. Install Filter

4. Open Tap, Bleed out air & adjust flow/pressure

5. Turn off after 10 liters

6. Remove outlet tubing and drain

7. Disconnect inlet tubing, seal capsule, bag, chill and ship

Lab FiltrationPotential for Additional Fees

39

Sample Elution

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Centrifugation

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Centrifugation

42

Pellet Size Potential for Additional Analytical Fees

43

Vortex

44

IMS

45

IMS cont.

46

IMS cont.

47

IMS cont.

48

Reading Slides

49

Under the Microscope

50

Multiple Cryptosporidium

Multiple Giardia

LT2 Round 1

• Scheduling

• Sample Collection

• Reporting and DCTS

• Quality Control

• Laboratory Attrition

51

Scheduling - Round 1

• All schedules and sampling plans had to be approved

by EPA

• EPA understaffed and fell behind approvals quickly

• Scheduling guidance and training was unclear early

• Schedules were not agreed to by laboratories

• Many labs became over capacity

• Some PWS were without a lab

52

Sample Collection – Round 1

• Sample temperature issues

• Bulk samples > 20 degrees C

• Filters frozen

• Missed matrix spikes

• Shipping of E. coli samples

• Missed collection dates

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Reporting & DCTS – Round 1

• Data Control and Tracking System (DCTS)

• All data entered manually in web forms

• Frequent crashes

• Very slow when operational

• Lab could not report results in oocysts/liter to client

• Created confusion for client

• Made bin calculation even more confusing

Quality Control – Round 1

• Matrix Spikes

• Average recoveries from 25 to 50%

• No recovery requirements

• High turbidity samples

• Some samples took 6-8 hours to read slides

• Matrix spike may have results of 0%

55

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Laboratory Attrition – Round 1

• 48 labs on EPA approved lab list

• Municipal labs

• State labs

• Commercial labs

• Several dropped out or were dropped

• Lost analysts

• Approval revoked

• Too few samples

• High materials cost

Resources & References

• LT2 Rule Cryptosporidium & E. coli Sample

Collection Recommendations Pocket Guide

http://water.epa.gov/lawsregs/rulesregs/sdwa/lt2/upload/epa817k06002.pd

f

• Parasites – Cryptosporidium

http://www.cdc.gov/parasites/crypto/

• Environmental Health Services (EHS) – Cryptosporidium,

Cryptosporidiosis

http://www.cdc.gov/nceh/ehs/topics/Cryptosporidium.htm

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http://water.epa.gov/lawsregs/rulesregs/sdwa/lt2/upload/epa817k06002.pdf

http://www.cdc.gov/parasites/crypto/

http://www.cdc.gov/nceh/ehs/topics/Cryptosporidium.htm

Thank you

58

Monica Van Natta

Account Manager

Eurofins Eaton Analytical

559-326-4396

[email protected]

long term 2 (lt2) surface water treatment rule...crypto level 19 system a system b source water...

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