Arsenic Rule Compliance Steps

Today’s Discussion

• Rule Requirements and Compliance Schedule
• Consumer Confidence Report (CCR) Reporting Requirements
• Compliance Planning Data Gathering
• Assessment of Treatment Technologies
• Monitoring and Compliance
• Variances and Exemptions
• Resource Assistance

Arsenic Rule Requirements

• January 22, 2001 Final Rule Published
  • February 22, 2002 Effective Date
• Applies to CWS and NTNCWS
• Maximum Contaminant Level (MCL) = 0.01 mg/L (10 ppb)
  • Compliance with MCL Required by January 23, 2006
• MCL Goal (MCLG) = 0 ppb

Arsenic Rule Requirements

• Consumer Confidence Report (CCR) Reporting Requirements
  • Effective February 22, 2002
• Clarifications to Compliance and New Source Contaminant Monitoring for IOCs, VOCs, and SOCs
  • Effective January 22, 2004

CCR Reporting Requirements

CCR Reporting Requirements
25-50 ppb

• Current Educational Statement
  • "EPA is reviewing the drinking water standard for arsenic because of special concerns that it may not be stringent enough. Arsenic is a naturally-occurring mineral know to cause cancer in humans at high concentrations."
• Alternate Language Allowed with ADEQ Approval

CCR Reporting Requirements
> 50 ppb

• Current Health Effects Language
  • "Some people who drink water containing arsenic in excess of the MCL over many years could experience skin damage or problems with their circulatory system, and may have an increased risk of getting cancer."

CCR Reporting Requirements
> 5 ppb but <=10 ppb

• New Educational Statement
  • "While your drinking water meets EPA’s standard for arsenic, it does contain low levels of arsenic. EPA’s standard balances the current understanding of arsenic’s possible health effects against balancing the costs of removing arsenic from drinking water. EPA continues to research the health effects of low levels of arsenic which is a mineral known to cause cancer in humans at high concentrations and is linked to other health effects such as skin damage and circulatory problems."
• Alternate Language Allowed with ADEQ Approval

CCR Reporting Requirements
>10 ppb but <=50 ppb

• New Health Effects Language
  • "Some people who drink water containing arsenic in excess of the MCL over many years could experience skin damage or problems with their circulatory system, and may have an increased risk of getting cancer."

Compliance Planning
Data Gathering

• Assess Distribution System
  • Determine Potential Non-Treatment Options
    • Replace source and abandon
    • Blend with low level sources
    • Conduct hydrogeologic evaluation to determine if well can be modified to draw lower conc. arsenic

Compliance Planning
Data Gathering

• Assess Distribution System
• Determine Treatment Options
  • Individual wellhead treatment
  • Combine multiple sources for centralized treatment
• Issues to Consider
  • Current treatment - disinfection or no treatment
  • Land availability for treatment
  • Chemical usage (e.g., acids) by operators in neighborhoods
  • Increased trucking
  • Acceptable water loss from treatment
  • Residual/waste handling options -- sewer, landfill, hazardous waste facility

Compliance Planning
Data Gathering

• Review and Assess Existing Source Water Quality
• Determine Arsenic Levels
  • Speciate, Especially if Non-Chlorinated System
  • As(III) and As(V)
• Determine Levels of Competing Contaminants
  • pH, fluoride, chloride, nitrate, silica, TDS, sulfate, phosphate, and selenium
• Determine if Targeting to Remove Other Contaminants (e.g. nitrate, TDS, etc.)
• Determine Additional Data Needs

Assess Treatment Technologies

• EPA Listed Best Available Technologies "BAT" for Small System Compliance Technologies
  • Activated Alumina (Centralized & POU)
  • Coagulation/Filtration (>500 only)*
  • Coagulation-Assisted Microfiltration (> 500 only)
  • Electrodialysis Reversal (> 500 only)*
  • Enhanced Coagulation/Filtration
  • Enhanced Lime Softening (pH >10.5)
  • Ion Exchange
  • Lime Softening (> 500 only)*
  • Oxidation/Filtration*
  • Reverse Osmosis (Centralized >500 Only & POU)

    * EPA states "unlikely technology"

Assess Treatment Technologies

• Emerging Technologies
  • Granular Ferric Hydroxide
  • Modified Aluminas
  • Sulfur Modified Iron
  • Microsand Ballasted Sedimentation
• Continuing Technology Development

Treatment Technology Testing

• Most BAT Technologies Will Not Be Appropriate for Arizona Waters
• Bench Scale Tests
  • Assess Different Media and Manufacturers
  • Determine Chemical Feed Requirements
• Pilot Scale Tests
  • Verify Treatment Technology Meets Removal Goals
  • Determine O&M Costs
• Pretreatment and Residuals Treatment
• Full Scale Treatment

Monitoring

• Current Rule - Continue Under Current Monitoring Schedule
  • 2002-2004 Compliance Period
• New Rule - Initial Monitoring Schedule
  • Starts in 2005-2007 Compliance Period
    • SW systems -- January - December 31, 2006
    • GW systems -- January - December 31, 2007

Monitoring

• Monitoring Locations & Frequencies "Mirror" Phase II/V Rule
  • Each POE
  • GW Sources -- 1 Time Every 3-years
  • SW or GWUDISW Sources -- 1 Time Each Year
  • ADEQ Can Require More Frequent Monitoring
• Report Arsenic Results to Nearest 0.001 mg/L

Compliance

• Violation if MCL Exceeded at Any POE
• Annual or Less Frequent Monitoring
  • Compliance Based on Single Sample or Average of Single Sample with Confirmation Sample(s)
  • MCL Exceedance Triggers Quarterly Monitoring
• More Frequently than Annual Monitoring
  • Compliance Based on Running Annual Average at Each POE
  • MCL Exceeded if Any One Sample Causes Running Annual Average to Exceed Annual Running Average

Variances and Exemptions

• Difficult to Obtain V. or E. Due to Requirements
• Variance
  • System Cannot Meet MCL Due to Raw Water Characteristics
  • Alternate Water Sources Are Not Reasonably Available
  • System Must Install BAT Technology
  • Resultant Water Quality Will Not Result in Unreasonable Risk to Health
  • ADEQ Coordination and Approval with EPA Approval
  • Public Notice and Hearing Required

Variances and Exemptions

• Exemption -- Due to "Compelling Factors", System in Unable to Comply or Develop Alternate Water Supply Source -- Extends Compliance Time Frame
  • Water Quality Will Not Result in Unreasonable Risk to Health
  • Must Demonstrate Management or Restructuring Changes Cannot Be Made
    • Rate increases, accounting or ownership changes, contractual agreement for joint operation with multiple systems, or physical consolidation of water systems cannot be accomplished
  • Specified Time Period -- Max. 3-Years
    • > 3,300 with financial hardship renewals up to 6-extra years
  • ADEQ Coordination and Approval with EPA Approval

Resources

• AwwaRF Spreadsheet "Arsenic Costs and Issues"
  • Web-Based Computer Tool
    • Arsenic decision tree
    • Treatment optimization tool
• ADEQ/WIFA Technical Assistance Programs
• ASUA
• Larger Utilities
• Consultants