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IMPORTANT FYI…Regarding Proposed Rulemaking (25 Pa. Code Chapter 109) Disinfection Requirements Rule (45 Pa. B. 857)

IMPORTANT FYI

Please the attached letter from Doug Crawshaw, TAC Representative for the PA Section – AWWA, regarding the Disinfection Requirements Rule:

I suggest all of you familiarize yourselves with the changes, assess your impact and participate in the Public Comment Period. The public comment period will be open until April 19, 2016. This is the chance to have your voice heard and to possibly impact the course of this legislation.

1) Speak at one of the public hearings (see below), -or-

2) Submit written comments to the EQB (Environmental Quality Board) http://www.ahs.dep.pa.gov/eComment/ should be open for comments, soon, -or-

3) Write to and speak with your TAC and EQB representatives.

 

Three public hearings have been scheduled for the following dates:

– 3/28/16, 1:00 PM, DEP Southcentral Regional Office, 909 Elmerton Ave., Harrisburg

– 4/5/16, 1:00 PM, DEP Southeast Regional Office, 2 E. Main St., Norristown

– 4/7/16, 1:00 PM, DEP Southwest Regional Office, 400 Waterfront Dr., Pittsburgh

 

RE: Regarding Proposed Rulemaking
(25 Pa. Code Chapter 109)
Disinfection Requirements Rule
(45 Pa. B. 857)
March 19, 2016

Letter from: Douglas J. Crawshaw
PA-Section, AWWA TAC Board Representative
Water Quality Manager for The York Water Company
doug.paawwa.tac@yorkwater.com

Dear AWWA Member,

My name is Douglas Crawshaw and I’m writing to introduce myself to you as the newest TAC Board (Small Water Systems Technical Assistance Center) representative for the PA-Section – AWWA, which is presently engaged in commenting on two separate drinking water regulatory packages.

The first is the Proposed Disinfection Requirements Rule (revisions. to Chapter 109) which has been separated from the second, the RTCR (Revised Total Coliform Rule). Compliance with the Federal RTCR begins in less than one month, April 1, 2016.

Below are some highlights of the proposed Disinfection Requirements Rule legislation and then listed are some of the common points of contention for some suppliers.

– Minimum distribution system chlorine residuals at all points in the distribution system will be increased from 0.02 mg/L to 0.2 mg/L (a near ten-fold increase). The residual requirement is the same for total or free Cl2 residuals.
– New compliance monitoring for the new distribution system Cl2 residual must be conducted on a weekly basis as per a sample siting plan.
– Daily log inactivation values will now need to be reported to PADEP for surface water and GUDI systems. Language suggests that systems failing to maintain appropriate log inactivation for 4-hrs or longer would receive a Tier I violation.
– HPC (Heterotrophic Plate Count) is being removed as an option to nullify or invalidate a low distribution system chlorine residual result.
– Minimum entry point residual will need to be reported to the nearest hundredth. The reported value must be greater than 0.20 mg/L instead of 0.2-mg/L, implying a 0.01-mg/L level of precision. Many recording instruments do not possess this level of precision.
– Nitrification Control Plans will be required for systems that chloraminate.

Some notable and common points of contention amongst some water suppliers and the Department are:

1) Legionella – Does it belong in the preamble, especially if it is a premise plumbing issue?
2) Premise Plumbing – The Dept. maintains that there is shared responsibility; so where is the dividing line between the utility’s responsibility and that of the customer?
3) How do you rate the statements and claims that were included in the preamble? What do you agree / disagree with, and why?
4) How much will compliance cost for your system? Small systems with strip charts may wish to consider costs associated with connectivity to recording devices, costs of recording devices, programming (if any?), O&M, and replacement/spares, and if new analyzers will be required. Increased sampling and analysis costs will be incurred for many small systems with the weekly Cl2 sampling requirement. How about the costs to comply for medium or large systems?
5) Should HPC be eliminated as an alternative to a Cl2 residual in any / all circumstances?
6) What components of a nitrification action plan should be regulated and what should be considered “guidance”?

Please share this information with your local and represented utilities and help ensure that they are aware of the possible changes to their regulations and requirements.
For full details and in case of any possible misinterpretations in the above, please review the below links.

The Proposed Disinfection Req. Rule can be viewed here: http://www.pabulletin.com/secure/data/vol46/46-8/278.html.

The PADEP has a webpage providing some information regarding the Proposed Disinfection Requirements Rule as well as other links can be viewed here: http://www.dep.pa.gov/Business/Water/BureauSafeDrinkingWater/DrinkingWaterMgmt/Regulations/Pages/Proposed-Disinfection-Requirements-Rule–.aspx

I suggest all of you familiarize yourselves with the changes, assess your impact and participate in the Public Comment Period. The public comment period will be open until April 19, 2016. This is the chance to have your voice heard and to possibly impact the course of this legislation.

1) Speak at one of the public hearings (see below), -or-

2) Submit written comments to the EQB (Environmental Quality Board) http://www.ahs.dep.pa.gov/eComment/ should be open for comments, soon, -or-

3) Write to and speak with your TAC and EQB representatives.
Three public hearings have been scheduled for the following dates:
– 3/28/16, 1:00 PM, DEP Southcentral Regional Office, 909 Elmerton Ave., Harrisburg
– 4/5/16, 1:00 PM, DEP Southeast Regional Office, 2 E. Main St., Norristown
– 4/7/16, 1:00 PM, DEP Southwest Regional Office, 400 Waterfront Dr., Pittsburgh

Thank you,

Douglas J. Crawshaw
PA-Section, AWWA TAC Board Representative
Water Quality Manager for The York Water Company
doug.paawwa.tac@yorkwater.com

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