Hot Topics with Ohio EPA September, Susan Schell Manager Engineering & Infrastructure DDAGW

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1 Hot Topics with Ohio EPA September, 2017 Susan Schell Manager Engineering & Infrastructure DDAGW

2 Outline Manganese Compliance Strategy Corrosion Control What s new Asset Management SB2

3 Manganese Health Concerns The main target of manganese toxicity is the central nervous system In children it can result in lowered intelligence quotient (IQ), poor motor functions, decreased attention span and hyperactivity Young children are especially at risk since they absorb more than their digestive systems can release In the elderly, it can cause a disorder similar to Parkinson s disease.

4 Manganese in Ohio

5 Health Advisory Levels (HALs) Manganese being looked at on UCMR4 USEPA established HALs for manganese in 2012 Point of compliance is entry point to the distribution system Health Advisories (HAs) provide information on contaminants that can cause human health effects and are known or anticipated to occur in drinking water

6 HALs for Manganese One-day Ten-day Life-time 1 mg/l 1 mg/l 0.3 mg/l

7 HALs for Manganese Manganese levels below 0.3 mg/l are generally not a health concern. Infants should not consume water that is above the life-time Health Advisory Level (HAL) of 0.3 mg/l.

8 Future Rules In the future, we will be writing rules to require routine finished water monitoring for all community and nontransient noncommunity water systems, regardless of existing treatment, or lack thereof. This would provide an equivalent level of protection for the all customers of those systems.

9 Manganese Compliance Strategy The purpose of the Manganese Compliance Strategy is to protect people from manganese that may be in drinking water at concentrations that can affect human health. The strategy identifies manganese levels that will be used to make water use advisory decisions. It also provides monitoring guidelines and sampling protocols, and recommends contingency planning for public water systems. It will also ensure that treatment for the removal of manganese is being properly operated and maintained.

10 Raw Water Manganese When a raw water analysis shows manganese levels above the Secondary Maximum Contaminant Level (SMCL) for community and nontransient noncommunity water systems, in accordance with OAC , the system is notified of the options to provide treatment, use another source or connect to another PWS. Transient systems that have manganese in their raw water at the time of installing their source are informed of the risks of elevated manganese and treatment is recommended.

11 Existing PWSs With Fe/Mn/As Treatment Systems that treat for manganese or use permanganate solution as an oxidizing agent, are now required to monitor weekly for manganese and report the results to Ohio EPA. If a system is treating to remove iron, manganese is assumed to be present unless four quarters of sampling demonstrates otherwise

12 Response to Finished Water Exceedances (Comm & NTNC) When manganese is detected in the finished water above 0.3 mg/l, the system is required to immediately notify Ohio EPA and the County Health Department of the results If the level in the finished water is at or above 1 mg/l, the system is required to immediately issue a Do Not Drink advisory Confirmation samples may be allowed if they are rushed to the lab for analysis

13 Response to Finished Water Exceedances (Comm & NTNC) For levels between 0.3 mg/l and 1 mg/l, the local health department may require the system to issue a precautionary use advisory, depending on the sensitive population of customers being served by the water system, for example a school or a daycare

14 Response to Finished Water Exceedances (Comm & NTNC) The system must initiate an investigation of the water system components to determine the source of manganese Once the source has been determined, the appropriate remediation must be implemented on a schedule acceptable to the director

15 Response to Finished Water Exceedances (Comm & NTNC) The system must remain on the applicable advisories until the finished water is shown to be reliably and consistently below the HALs for manganese The system then must continue to complete operational optimization to produce a finished water below the SMCL

16 Response to Finished Water Exceedances at Transient PWSs If the level exceeds 0.3 mg/l, we will recommend removal treatment, drill new well or connection to another PWS If the level exceeds 1.0 mg/l, we will require removal treatment, or drilling of a new well or connection to another PWS

17 Source Water Surveillance Public water systems should be aware that raw water quality can change over time depending on demand for groundwater and seasonal changes for surface water To adequately treat the raw water, water systems should routinely monitor their raw water sources Yearly monitoring is recommended for all wells and monthly monitoring is recommended for surface water sources.

18 Legacy Manganese Legacy manganese in distribution system is to be avoided Manganese that enters the distribution system can be difficult to effectively remove because it forms a thin slime on pipe surfaces that is resistant to flushing Manganese can absorb other metals, such as lead, arsenic and chromium and later release them in slugs There are also some indications that manganese can inhibit the formation of scale on the inside of lead pipes

19 Corrosion Control HB 512 Require a new or updated corrosion control treatment study and plan not later than eighteen months after if: Change or addition of source. Substantial change in water treatment. Operate outside of acceptable ranges for lead, copper, ph, or other corrosion indicators. Any other event determined by the director to have the potential to impact the water quality or corrosiveness of water in the system.

20 Optimal Corrosion Control Defined as: Corrosion control treatment that minimizes the lead and copper concentrations at user s taps while ensuring that the treatment does not cause the water system to violate any national primary drinking water standard

21 Ohio EPA Guidelines Guidelines for Determining When Source or Treatment Changes Trigger New Optimal Corrosion Control Evaluation Developed based on U.S. EPA s Optimal Corrosion Control Treatment Evaluation Technical Recommendations for Primacy Agencies and Public Water Systems Research has shown that corrosion is dependent on many water quality parameters (WQPs) and that treatment or source water changes can have a significant impact on lead release

22 Ohio EPA Guidelines Specific examples of what types of changes would require plan approval are listed in the guidance If treatment is installed per OAC rule paragraph (D) or paragraph (E), the system will be required to complete two 6-month periods of WQPs and lead and copper monitoring

23 ORC (H) The director shall provide financial assistance from the drinking water assistance fund established under section of the Revised Code WSRLA offers 0% loans for 20 years for the replacement of lead service lines, nominations accepted at all times Planning loans are available for corrosion control studies, 0% for 5 years

24 Drinking Water Issues In Senate Bill 2 Asset Management required at all public water systems Expanded escrow and added financial assurance flexibility Set up receivership process

25 Asset Management Provisions Components: Inventory and evaluation of all assets Operation and maintenance programs Emergency preparedness and contingency planning program Criteria and timelines for infrastructure rehabilitation and replacement Approved capacity projections and capital improvement planning Long-term funding strategy to support asset management program implementation

26 Draft Asset Management Rules To mesh with the proposed statutory change and our existing capability rules, we have drafted rules to address the managerial, technical and financial capability of all water systems We will follow our typical rulemaking process, including stakeholder outreach and public comment Written asset management programs required by October 1, 2018

27 Managerial Capability Documentation of ownership Documentation of a certified operator Brief non-technical description of the water system

28 Managerial Capability Operating plan Written procedures Inventory of external contacts Internal contracting and purchasing procedures (routine and emergency)

29 Technical Capability Map Inventory of assets Evaluation of assets Level of service goals Metrics

30 Technical Capability Operation and maintenance programs Approved capacity projections Criteria and timeline for rehabilitation and replacement Capital improvement plan

31 Financial Capability Pro-forma statements (5 years previous and 5 years projected) Income statement Balance sheet Statement of cash flow

32 Financial Capability Amortization schedule for outstanding debt Capitalization terms of debt Current water rate ordinance and triennial water rate evaluation Documentation of all customers billed per metered water usage Information demonstrating bond or credit rating

33 Implementation Prioritizing systems requesting SRF loans, systems under enforcement and systems with obvious capability issues These systems will undergo a capability screening to identify areas of deficiency The systems asset management program will need to address these areas

34 Implementation At the time of sanitary surveys, inspectors will initially be asking to see some basic components, such as asset inventory, maps, level of service goals, metrics, etc. Submission of the written asset management program will only be upon the Director s request.

35 Implementation We are developing guidance for systems, expectations will vary based on system type and complexity We are developing templates for very small systems

36 Funding for Asset Management Planning loans are available Terms of 5 years at 0% interest Potential for $10,000 in principal forgiveness

37 Susan K. Schell (614) Questions

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