PUBLIC WATER SYSTEM PLAN and EXCEPTION REVIEW Plan

PUBLIC WATER SYSTEM PLAN and EXCEPTION REVIEW Plan Review Team David T. Smith, P. E. Technical Review and Oversight Team Erin Guerra, P. E. Plan and Technical Review Section Water Supply Division

Why Submit Plans? « Public Health and Safety Plan Review Team Mission: To ensure that public water system construction meets minimum standard public health and operational safety design criteria in compliance with federal and state statute and good engineering practices. «Law w Texas Health & Safety Code w Federal Safe Drinking Water Act 2

HEALTH and SAFETY …this is why we require review and maintenance! Ready for Pump Replacement? 3

Who Submits Plans? Professional Engineers (P. E. ) Licensed in the State of Texas ALL Public Water Systems* Cities, Districts, Non-profit or For-Profit, Wholesale or Retail, or Privately Owned Water Systems * That have 15 service connections or serve 25 or more individuals at least 60 days out of a year. 4

When Do We Submit Plans? « BEFORE STARTING CONSTRUCTION: No person may begin construction on a new public water system before receiving written approval of plans and specifications. § 290. 39(h)(1) « IF SIGNIFICANT CHANGE TO EXISTING SYSTEM IS PLANNED: Significant changes shall not be instituted without prior approval …. § 290. 39(j) 5

What’s A Significant Change? w Potential Health Hazard: § 290. 39(j)(1)(B)&(C) w Increase or Decrease § 290. 39(j)(1)(A) in Capacity: ~Distribution ~Treatment ~Production ~Pressure ~Storage 6

Significant Changes… Distribution Capacity (measured in connections) w Distribution expansion, waterlines (in connections) # of new connections <10% total existing connections and does not affect the ability to comply with capacity requirements or involves interconnection with another public water system 7

More Significant Changes… « Disinfection § 290. 39(j)(1)(B) w w Disinfectant Application point Monitoring point Residual § 290. 39(j)(1)(C) 8

Significant Changes «ANY OTHER MATERIAL CHANGES specified by TCEQ. § 290. 39(j)(1)(E) 9

Plans & Specs NOT Required « CHANGES NOT SIGNIFICANT? 1. Waterline additions less than 10% of the total connections 2. Waterlines subject to ordinance review A) ORDINANCE: Copy of local ordinance or statute requiring submittal to another state agency with its own internal review staff. § 290. 39(j)(2)(B) B) CERTIFICATION: Written 290 compliance certification by internal staff P. E. C) NOTIFICATION: Letter of notification to TCEQ. § 290. 39(j)(2)(B) 10

What To Submit? « Written Notification § 290. 39(h)(2) and/or Cover Letter « Submittal Form § 290. 39(h)(1)(2) « Engineering Report § 290. 39(e)(1) New system, SWTP, or deficiencies « Engineering Plans and Technical Specifications § 290. 39(j)(2)(B) « Business Plan § 290. 39(f) for Privately owned new public water systems 11

Plan Submittal Form • Must use unaltered TCEQ form only • Use latest revision of the form • Can be obtained from TCEQ Webpage • Sign and seal the form 12

ENGINEERING DRAWING Sign, seal, and date each page S E A L 13

CONSTRUCTION SPECIFICATIONS • BOUND WITH COVER PAGE • SIGNED, SEALED & DATED 14

What Else Is Submitted? Submit and Receive Approval for Following Prior to Plant Startup and PRIOR to Plan Review Submittal: « Exception Request for any changes from rule requirements « Pilot study w Change in source w New filtration rate w Alternative process (not conventional filtration) « CT* Study – 90 days prior / SWTP ____________________ *C = disinfectant residual concentration, T = time 15

Where Do We Send Plans? Mail: Plan Review Team - MC-159 Texas Commission on Environmental Quality P. O. Box 13087 Austin, TX 78711 -3087 Deliver: 12015 Park Circle, Bldg. F, 3 rd. Floor Austin, TX 78753 16

How Are Plans Processed? « RECEIVE ~ 180 Plans/Month « Given a Log Number and Entered into WUD database « Administrative Review « Assigned to Plan Reviewer « Reviewed by Engineering Staff* in order received 17

1 8 TYPES OF PROJECTS 2018 27% 37% [PERCE NTAGE] 2% 11% 21% Waterlines Wells Ground Water Treatment Plant Surface Water Treatment Plant Reverse Osmosis Others

WEB SITE http: //www. tceq. state. Texas. gov/drinking water/planrev. html New: Surface Water Checklists 19

Process Related Plans. Reviewed by Technical Review and Oversight Team « Disinfection: Chlorination/Chloramination w Chlorine Dioxide w Ozonation w UV « Treatment: w Conventional filtration w Package plants w Membranes w Ion Exchange w Innovative Technologies w Each project reviewed on a site specific basis 20

Exceptions: Proposing Another Way to Meet the Intent of the Rules Plan & Technical Review Section Technical Review and Oversight Team Erin Guerra, P. E. May 2019 21

Scope Learn the procedural requirements to request an exception to propose another way to meet the intent of the rules under 30 TAC 290, Subchapter D

Where do Exceptions Come From? « Allowed as described in 30 TAC § 290. 39 (l) w Each request is considered on an individual basis. w Must demonstrate that the exception will not compromise the public health or degrade the service or water quality.

2018 - Exceptions Received per Rule Section 24

Procedural Requirements When are exceptions allowed? Who can submit an exception request? What is required in the exception submittal? When do you submit exception requests? Where do you send exception requests? 25

When are Exceptions Allowed? « If a public water system (PWS) does not meet a TCEQ design standard, they may request an exception by proposing another way it can meet the intent of the rules. This Photo by Unknown Author is licensed under CC BY-NC-SA 26

Who Can Submit Exceptions? « Public Water Systems and their representatives w For almost any rule between § 290. 41 -. 46 « Professional Engineers licensed in Texas w Pilot study reports - § 290. 42(g) w Alternative Capacity Requirement requests for alternatives to elevated storage - § 290. 45(g)(5) 27

What is required in an Exception submittal? « TCEQ- 20659 « Signed cover letter « Proposed alternative, explanation, supporting documentation 28

What Else Is Submitted? Submit and Receive Approval for Following Prior to Plant Startup and PRIOR to Plan Review Submittal « Exception Request for any changes from rule requirements – 90 to 100 days « Pilot study w Change in source w New filtration rate w Alternative process (not conventional filtration) « CT* Study – 90 days prior / SWTP ____________________ *C = disinfectant residual concentration, T = time 29

When do you submit Exception Requests? « Before the PWS is locked into a course of action that will result in a deviation from the rules. « To comply in response to an alleged violation noted during a Comprehensive Compliance Inspection (CCI). « Before submitting engineering plans and specifications for review and approval. 30

Where Do You Submit Exception Requests? Technical Review and Oversight Team Plan and Technical Review Section, MC -159 Texas Commission on Environmental Quality P. O. Box 13087 Austin, TX 78711 -3087 31

Process Related Plans « Disinfection: w Blending Chlorine & Chloramines w Chlorine Dioxide w Ozone w Ultraviolet « Treatment: Conventional filtration w Package plants w Membranes w Ion Exchange w Innovative Technologies w Each project reviewed on a site specific basis 32

Help with Exception Submittals Staff Guidance Documents Checklists • Used by the public and TCEQ Staff • Available on TCEQ Website • Updated in 2018 • Documentation required https: //www. tceq. texas. gov/drinkingwater/trot/exception 33

How Long Does It Take TCEQ to Review the Request? « Each exception request is reviewed to ensure that, if granted, the PWS will still deliver safe drinking water to its customers at adequate pressures. Type Exceptions ACRs Timeframe 100 days 90 days 34

Last Things About Exceptions « Any granted exception can be revised or revoked. « As a condition of granting the exception the TCEQ may establish site-specific design, operation, maintenance, and reporting requirements for systems. 35

Financial, Managerial, & Technical (FMT) Assistance If you operate a water or wastewater system and would like to arrange for free financial, managerial, or technical assistance, contact our Financial, Managerial and Technical (FMT) program team: FMT@tceq. texas. gov https: //www. tceq. texas. gov/drinkingwater/fmt (512) 239 -4691

Small Business & Local Government Assistance Free confidential hotline 1 -800 -447 -2827 http: //www. texasenvirohelp. org

Questions? Water Supply Mainline: (512) 239 -4691 Plan Review Website www. tceq. texas. gov/permitting/water_supply/ud/planrev. html Exception Website http: //www. tceq. texas. gov/drinkingwater/trot/exception Water Supply General Email Box: PDWS@tceq. texas. gov