TCEQ Water Quality Parameter WQP Training WQPs Action

TCEQ Water Quality Parameter (WQP) Training WQPs & Action Level Exceeders November 6 & 7, 2017 Austin, Texas Laurie Gehlsen

What is an ALE? • Action Level Exceedance (ALE) is a 90 th percentile value above the LCR action level for either lead or copper • Lead Action level = 0. 015 mg/L • Copper Action level = 1. 3 mg/L 2

Steps After ALE • Tap water sampling (every six months) • Entry point lead and copper sampling • WQP sampling • Source water & optimal corrosion treatment recommendation 3

Steps After ALE • Corrosion Control Study OR • Deemed under “Small System Cessation” • 30 TAC § 290. 117(f)(6) 4

Time Steps After ALE If applicable • Install treatment • WQP Sampling • Optimal Water Quality Parameter numbers • WQP Sampling • GOAL: Optimized corrosion control 5

Rule Of Thumb • During ALE, PWS sampling Distribution System & Entry Points Lead and Copper Source Entry Points WQPs Lead and Copper addresses 3 areas simultaneously: Premise Plumbing 6

WQP & ALE • An ALE triggers ROUTINE WQP sampling at locations in distribution system based on PWS population • All WQPs are sampled on a ROUTINE schedule 7

WQP Locations – How many sites? System Size (# of People Served) >100, 000 Initial/Routine # of Sites for WQPs 25 10, 000 - 100, 000 10 3, 301 - 10, 000 3 501 - 3, 300 2 101 - 500 1 <101 1 8

WQP Locations – Where at? • WQP sampling at each Entry Point • (after treatment before distribution or first service connection) • WQP sampling in Distribution System 9

WQPs in Distribution • Fully flushed samples (approx. 5 mins) • Outside sample stations or hose bibs – representative of the Distribution System, not the building 10

ALE WQP Sampling • WQPs collected within 6 months of the beginning of the monitoring period • Example 1: PWS on YR or 3 YR schedule > ALE triggered Tap sample monitoring period is June 1 – September 30 • WQP samples are due Nov. 30 11

ALE WQP Sampling • Example 2: PWS on 6 M 1 schedule > ALE triggered Tap sample monitoring period is January 1 - June 30 • WQP samples are due December 31 same year 12

ALE WQP Sampling • Example 3: PWS on 6 M 2 schedule > ALE triggered Tap sample monitoring period is July 1 – December 31 • WQP samples are due June 30 following year 13

ALE WQP Sampling • Beginning with the upcoming monitoring period, quarterly WQP sampling begins: • Example 1: YR or 3 YR tap sample monitoring = begin the next January and sample in Q 1, Q 2, Q 3, and Q 4 in the year following ALE. 14

ALE WQP Sampling • Example 2: 6 M 1 tap sample monitoring = start July and sample in Q 3 & Q 4 in the same year as ALE and Q 1 & Q 2 in the year following ALE. 15

ALE WQP Sampling • Example 3: 6 M 2 tap sample monitoring = start January and sample in Q 1, Q 2, Q 3, and Q 4 in the year following ALE. 16

ALE WQP Results • WQP results taken during time of exceedance +1 st quarter of the following monitoring period • used in the Optimal Corrosion Control Treatment (OCCT) recommendation • due 180 days after the end of the exceeding monitoring period. 17

ALE Recommend OWQPs • PWS recommends optimal water quality parameter ranges for p. H, alkalinity and treatment type (i. e. orthophosphate) at locations in distribution and at each entry point • 30 TAC § 290. 117(e)(4) 18

ALE WQP Levels • If treatment has been added, and OWQPs have been recommended: • PWS will be required to sample and stay within the OWQP level ranges 19

ALE Continuous WQPs • WQP sampling after OWQP range designation • Entry points = at least every two weeks • Distribution points = quarterly 20

ALE Reduced WQPs • Distribution system sampling = can reduce from quarterly to annual to every three years • Entry point sampling = remains every two weeks 21

ALE Reduced WQPs • Reduced WQP list: • p. H • alkalinity if adjusted as part of corrosion control • Dosage rates and concentration • calcium if calcium carbonate stabilization is used for corrosion control 22

ALE Reduced WQPs • Orthophosphate or silica if part of the inhibitor • Inhibitor dosage rate and residual • 30 TAC § 290. 117(e)(5) 23

ALE PWS Example • PWS has population of 2, 938 • PWS on 3 YR tap water sampling schedule 2015 – 2017 • PWS collects lead and copper tap water samples on July 15, 2017 24

ALE PWS Example • Triggers lead ALE – no longer deemed to have optimal corrosion control • Completes Lead Consumer Notice within 30 days 25

ALE PWS Example • Collects WQP samples at entry point and at 2 locations in distribution system on August 10 2017 • Completes Lead Public Education on September 1 2017 • Collects lead and copper entry point sampling on October 4 2017 26

ALE PWS Example • Completes source water treatment recommendation on November 5 2017 – Form 20755 • Collects WQP samples at entry point and at 2 locations in distribution system for Q 1 on January 15, 2018 • Collects lead and copper tap water sampling on February 12, 2018 27

ALE PWS Example • Completes optimal corrosion control treatment recommendation using 2017 and Q 1 2018 WQP data on March 12 2018 • Collects WQP samples at entry point and at 2 locations in distribution system for Q 2 on May 13 2018 28

ALE PWS Example • Collects lead and copper tap water samples on July 5 2018 • If both 90 th percentile results are below the AL, the PWS is deemed to have optimal corrosion control without completing a corrosion control study and all sampling stops 29

ALE PWS Example • If one of the 90 th percentile results are above the AL for either 6 -month lead and copper tap water sampling, the PWS is required to complete a corrosion control study and install treatment. • 30 TAC § 290. 117(f)(1)(A)(ii) 30

QUESTIONS Laurie Gehlsen TCEQ Lead and Copper Rule Team 512 -239 -4660