Water Quality Parameter Monitoring Lead and Copper Rule

Transcription

1 Water Quality Parameter Monitoring Lead and Copper Rule Federal Citations Water Quality Parameter Monitoring: 40 CFR Kat Burkhard April 2016 What Size System am I under the Lead and Copper Rule? Water Quality Parameter (WQP) Monitoring Size Category Population Served* Large > 50,000 Medium 3,301 50,000 Small < 3,300 * Transient populations served are not factored in to the population served Objectives Determine water corrosivity Identify appropriate corrosion control treatment Determine whether corrosion control treatment is being properly maintained Schedule Types Initial Follow Up Optimal Person Acceptable to the State Sample Collection & Analysis Certified Laboratory or by Person Acceptable to the State Licensed Operator or someone trained by a Licensed Operator Use analytical methods in 40 CFR (k)(1) Conduct proper calibrations and maintain records of all QAQC tasks Submit results on the Excel Generic WQP Analysis Spreadsheet via to watersupply@dep.nj.gov 1

2 When is Initial WQP Monitoring Required Initial WQP Monitoring Small & Medium Systems Within 6 months of the beginning of the monitoring period in which the lead and/or copper action level was exceeded January June July December June November Systems that have already started follow up or optimized monitoring don t trigger back to initial monitoring even if exceed an action level Initial Parameters & Frequency Calcium Conductivity Temperature 2 sets of samples at each Point of Entry and Distribution Tap Each set must be collected on different days and should account for seasonal variability Required # of distribution taps is based on population 40 CFR (a)(2) Corrosion Control Treatment (CCT) Recommendation Submit recommendation within 6 months from end of monitoring period June 30 th, December 31 st, or March 30 th Recommend 1 or more of the following: adjustment adjustment Calcium hardness adjustment Phosphate/silicate based corrosion inhibitor CCT Recommendation Approved Install approved CCT process within 24 months Required to obtain proper approvals/permits from administrative authority Within 30 days of installation submit: Construction Completion Certification OR CCT Installation Certification Form Follow Up After CCT Installed 2

3 When is Follow Up WQP Monitoring Required? Follow Up Parameters & Frequency 2 consecutive 6 month monitoring periods immediately following installation of CCT Begins January 1 st or July 1 st, whichever is sooner Lead and Copper tap monitoring also required during these 2 consecutive 6 month monitoring periods Point of Entry Biweekly Dosage rate of chemical Distribution Taps Required # of distribution taps is based on population 40 CFR (a)(2) 2 sets of samples collected on different days (should account for seasonal variability) Calcium Setting Optimal WQP Values Submit recommended optimal WQP values within 30 days of completing follow up monitoring Recommend for each WQP at each POE and distribution system Division will only be setting minimums Optimal After State has Set Optimal WQP Values When is Optimal WQP Monitoring Required? Optimal Parameters & Frequency Each 6 month monitoring period after Division sets Optimal WQP Values Beginning January 1 st or July 1 st, whichever is sooner All systems, regardless of size, will be required to conduct this monitoring for all monitoring periods in which the system is in operation Point of Entry Biweekly Dosage Rate of Chemical Distribution Taps Required # of distribution taps is based on population 40 CFR (a)(2) 2 sets of samples collected on different days (should account for seasonal variability) Calcium 3

4 Is My System Eligible for Reduced Optimal WQP Monitoring? Maintain Optimal WQP Values for 2 consecutive 6 months? Reduce # of distribution taps [40 CFR (a)(2)] Maintain Optimal WQP Values for 3 consecutive years (6 consecutive 6 months) Sample at reduced # of distribution taps annually Maintain Optimal WQP Values for 3 consecutive annual monitoring periods Sample at reduced # of distribution taps triennially Compliance Determinations State Designated Optimal WQP Values How Often is Level Compliance Determined? Each 6 month compliance period January June July December 3 Step Process Calculation of Daily Values Determine duration of excursion Determine if Treatment Technique Violation Monitoring Frequency More than Daily Daily Biweekly Semi Annually Annually/Trie nnially Daily Value Calculation Average all results measured for each parameter at each sampling location Result of each daily sample for each parameter at each sampling location Result of the biweekly sample for each parameter at each sampling location* Result of the semi annual sample for each parameter at each sampling location* Result of the annual/triennial sample for each parameter at each sampling location* Step 1: Calculation of Daily Values *Days in which no samples were collected on, the daily value is the most recent result taken at that location, even if the result is from a previous monitoring period 1. Count the 1 st day with a result below the minimum value set by the State 2. Stop counting days when a sample result from the same location and for the same parameter is equal to or greater than the minimum value set by the State 3. Repeat 1 and 2 above every time a result is below the minimum value set by the State during the 6 month period being evaluated Step 2: Determine Duration of Excursion Excursion Any daily value for a parameter that is below the minimum value set by the State Step 3: Determine Treatment Technique Violation Cannot be outside the set Optimal WQP Values for more than a total of nine days at: A specific sampling point or combination of sampling points OR For a specific WQP or combination of WQPs Consider unresolved excursions from a previous monitoring period 4

5 Example 1 Example 1: Point of Entry Small system serving < 500 Required # of distribution taps = 1 One Point of Entry with ph adjustment and phosphate based corrosion inhibitor Point of Entry ph= 7.0 Orthophosphate = 1.0 ppm Distribution System ph = 7.0 Orthophosphate = 0.5 ppm January January January February February March March April April May May June June February May May Point of Entry: 3 days out of compliance Example 1: Distribution Tap Example 1: Point of Entry & Distribution Tap Excursions February May February February Distribution Tap: 2 days out of compliance Date of Excursion Point of Entry Distribution Tap February 13 February 14 May 22 May 23 4 Excursions for this 6 month monitoring period Example 2: Multiple Distribution Taps Example 3: Unresolved Excursion A sample collected at one location cannot be used to demonstrate compliance at a different sampling site Sample Date Distribution Tap 1 Distribution Tap 2 February May May No sample collected May No sample collected Consider unresolved excursions from a previous monitoring period Sample Date Distribution Tap 1 Distribution Tap 2 February May May No sample collected May No sample collected July November

6 What do I Need to Do? Treatment Technique Violation 9 or more excursions in a 6 month compliance period Report violation to NJ DEP within 48 hours Deliver public notice (Tier 2) Include discussion of violation in CCR Return to standard (every 6 months) WQP tap monitoring AND lead and copper tap monitoring Applicability & Content WQP Sampling Plans All systems required to conduct Lead and Copper monitoring should have a WQP Sampling Plan Monitoring frequency/schedule for POE and DS taps Identify which WQPs are required to be monitored Standard, reduced, and alternate sites Site selection justification Distribution Map Sample Collection & Analysis Procedures Action Plans Resources EPA s Lead and Copper Rule Monitoring and Reporting Guidance for Public Water Systems By the time you feel thirsty, your body has lost more than % of its total water. EPA s How to Determine Compliance with Optimal Water Quality Parameters as Revised by the Lead and Copper Rule Minor Revisions Good hydration can prevent. 6

7 Questions Kat Burkhard Bureau of Water System Engineering