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Transcript of 1 If you do not have a copy of the SWTRs handouts, a copy can be downloaded from the Encounter...
1
If you do not have a copy of the SWTRs handouts, a copy can be downloaded from the Encounter Collaborative meeting page:https://ei.e2c.com/enc/enc-pc.pmtg
2
Encounter Customer Care
General Technical Support at Encounter
800-290-5900, Option 1
Or press *0 on your telephone when dialed into your Express, Priority, or Broadcast Number to be transferred directly to Customer Care.
How many people are attending at your location? 1 Person 2 - 4 People 5 - 10 People 10 - 20 People More than 20 People
4
Evaluation Form – Available on the web at:
• http://yosemite.epa.gov/ogwdw/ogwdwsurvey.nsf/surveyhome?openform
• Enter code: survey07 Please email [email protected] if
you have questions
New
5
Happy Sweet Sixteen!!!!!!!!
June 29, 1989 June 29, 2005
6
Surface Water Treatment Rules (SWTRs)
U.S. EPA
Webcast Training Session
June 29, 2005
2:00-4:00pm EST
7
SWTRs
SWTRs Training encompasses requirements of the following regulations:
• Surface Water Treatment Rule (SWTR)
• Interim Enhanced Surface Water Treatment Rule (IESWTR)
• Long Term Enhanced 1 Surface Water Treatment Rule (LT1ESWTR)
• Filter Backwash Recycling Rule (FBRR)
8
SWTRs Size Filtration Type SWTR
1989
IESWTR
1998
LT1
2002
FBRR
2001
Serving at least 10,000
Conventional or Direct Filtration
Slow Sand, Diatomaceous Earth or Alternative Filtration
Unfiltered Systems
Serving fewer than 10,000
Conventional or Direct Filtration
Slow Sand, Diatomaceous Earth or Alternative Filtration
Unfiltered Systems
9
SWTRs Purpose
Purpose: To improve public health protection through the control of microbial contaminants, including requirements for removal and/or inactivation of:
• Viruses
• Giardia Lamblia
• Cryptosporidium
10
SWTRs Scope
Scope:
• Applies to all public water systems using surface water or ground water under the direct influence of surface water (GWUDI), otherwise known as “Subpart H systems.”
Require all Subpart H systems to:• Disinfect
• Filter
• Individual filter monitoring & establishes CFE limits
• Apply treatment technique requirements for control of microbials.
Exception – Systems meeting Filter Avoidance Criteria only need to disinfect
11
Outline History of Microbials Overview of SWTR, IESWTR, and LT1ESWTR
Requirements Disinfection Profiling and Benchmarking
• Lessons Learned in the Process (City of Manassas, VA) Other Requirements under the SWTR Turbidity Requirements
• Conventional and Direct Filtration Systems • Systems using Slow Sand, Diatomaceous Earth or Alternative
Filtration• Unfiltered Systems
Case Studies Additional Resources
Overview
12
The requirements that apply to each system depend on the system’s treatment
process.
Applicability to Systems
This presentation covers:
• Conventional and Direct Filtration Systems
• Slow Sand and Diatomaceous Earth or Alternative Filtration Systems
• Unfiltered Systems
Overview
13
Presenters
Ed Moriarty, U.S. EPA
Maria Lopez, U.S. EPA
Linda Hills, The Cadmus Group, Inc.
Tom Grubbs, U.S. EPA
Mike Finn, U.S. EPA
Panelists
Overview
14
Disclaimer
The examples included in this presentation are intended for discussion purposes only. Throughout this presentation, the terms “state” or “states” are used to refer to all types of primacy agencies including U.S. territories, Indian tribes, and EPA Regions. The statutory provisions and EPA regulations described in this document contain legally binding requirements. This presentation is not a regulation itself, nor does it change or substitute for those provisions and regulations. Thus, it does not impose legally binding requirements on EPA, states, or public water systems. This guidance does not confer legal rights or impose legal obligations upon any member of the public. While EPA has made every effort to ensure the accuracy of the discussion in this presentation, the obligations of the regulated community are determined by statutes, regulations, or other legally binding requirements. In the event of a conflict between the discussion in this presentation and any statute or regulation, this presentation would not be controlling.
Overview
15
Public Health & Regulated Pathogens
Regulated Pathogens:
• Viruses
• Giardia
• Cryptosporidium
In excess amounts:
• Nausea
• Cramps
• Diarrhea
• Associated headaches
• More serious health effects for infants, elderly or other immune-compromised people
Overview
16
History of Microbials
17
The Challenge of Microbial Organisms What They Do Was Known
Before What They Are
• Hippocrates: Boil and Strain Water ~300BC
• Chlorination to Prevent ‘Child Bed Fever’ - 1846
• John Snow Closes the Broad Street Well, London, 1854 - Terminates Cholera Epidemic
What They Do Was Known Before How To Detect Them In Drinking Water
Overview
18
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
19
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
1974 – Safe Drinking Water
Act (SDWA)
Overview
20
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
21
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
1976 – National Interim Primary Drinking Water Regulations (NIPDWR): Coliform and Turbidity
22
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
23
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
1986 – Safe Drinking Water Act Amendments (SDWA
Amendments)
24
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
25
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
1989 – Total Coliform Rule (TCR); Surface Water
Treatment Rule (SWTR)
26
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
27
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
1996 – Safe Drinking Water Act Amendments (SDWA
Amendments)
28
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
29
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
1998 – Interim Enhanced Surface Water Treatment Rule
(IESWTR); Stage 1 Disinfectants and Disinfection Byproducts
Rule (S1DBPR)
30
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
31
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
2001 – Filter Backwash
Recycling Rule (FBRR)
32
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
33
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
2002 – Long Term 1 Enhanced Surface Water Treatment Rule
(LT1ESWTR)
34
History of M-DBP Regulations
THM – 1979 NPIDWRs –
1976 SDWA – 1974
MA Giardia Outbreak – 1985
SDWA Amendments – 1986
GA Crypto Outbreak – 1987 MO E. Coli Outbreak – 1989 TCR and SWTR – 1989
WI Crypto Outbreak – 1993 SDWA Amendments – 1996
IESWTR and S1DBPR – 1998
FBRR – 2001
2005 – Proposed S2DBPR, LT2ESWTR, GWR
200? – Future Rules: Revised TCR
LT1ESTWR – 2002
Overview
35
National Interim Primary Drinking Water Regulations (NIPDWR) Effective from 1975 to 1986 SDWA Amendments
Total Coliform Monitoring and MCL Based on USPHS Drinking Water Regulations of 1962
Turbidity MCL for Surface Water
Recognized Underreporting of Outbreaks
Overview
36
1996 SDWA Amendments
No Significant Changes to the Total Coliform Rule Required Promulgation of Microbial/Disinfection
Byproduct Regulations
• IESWTR, LT1ESWTR, FBRR, LT2ESWTR
• Stage 1 and 2 Disinfectants and Disinfection Byproducts Rules
Overview
37
6-Year Review Cycle
SDWA Requires Review of Existing Regulations The Total Coliform Rule is Under Review
• Schedule to Be Determined
Overview
38
Types of Filtration:
Conventional Filtration Direct Filtration Slow Sand Filtration Diatomaceous Earth Filtration Alternative Filtration Technologies
Overview
39
Requirements for Filtered Systems
Removal/Inactivation Requirements for Certain Pathogens
Residual Disinfectant Requirements Turbidity Treatment Techniques Disinfection Profiling and Benchmarking Sanitary Surveys Covered Finished Reservoirs/Water Storage Facilities Operator Certification
Overview
40
Requirements for Unfiltered Systems
Inactivation Requirements for Certain Pathogens Residual Disinfectant Requirements Filtration Avoidance Criteria Disinfection Profiling and Benchmarking Sanitary Surveys Covered Finished Reservoirs/Water Storage Facilities Operator Certification
Overview
41
Questions
Please send your questions & comments via the web console located on your bottom right.
Q & A
42
Overview of SWTR, IESWTR, and LT1ESWTR Requirements
Conventional and Direct Filtration Systems
Systems using Slow Sand, Diatomaceous Earth or Alternative Filtration
Unfiltered Systems
43
General Requirements
All Subpart H systems must comply with the following requirements:
• Removal/inactivation requirements for viruses, Giardia, and Cryptosporidium
• Residual disinfectant monitoring
• Disinfection profiling and benchmarking
• Sanitary surveys
• Covered finished reservoirs/water storage facilities
• Qualified operators
Unfiltered Systems
Conventional and Direct
Filtration
Slow Sand, Diatomaceous or Alternative
Filtration
44
Regulated Pathogens (Removal/Inactivation Requirements) All subpart H systems must comply with the
removal/inactivation requirements established for regulated pathogens. The removal/inactivation requirements are as follows:
Microbial MCLGRemoval/Inactivation
Requirements
Viruses 99.99% (4-log)
Unfiltered Systems
Conventional and Direct
Filtration
Slow Sand, Diatomaceous or Alternative
Filtration
45
Regulated Pathogens (Removal/Inactivation Requirements) All subpart H systems must comply with the
removal/inactivation requirements established for regulated pathogens. The removal/inactivation requirements are as follows:
Microbial MCLGRemoval/Inactivation
Requirements
Viruses 99.99% (4-log)
Giardia Lamblia Zero 99.9% (3-log)
Unfiltered Systems
Conventional and Direct
Filtration
Slow Sand, Diatomaceous or Alternative
Filtration
46
Regulated Pathogens (Removal/Inactivation Requirements) All subpart H systems must comply with the
removal/inactivation requirements established for regulated pathogens. The removal/inactivation requirements are as follows:
Microbial MCLGRemoval/Inactivation
Requirements
Viruses 99.99% (4-log)
Giardia Lamblia Zero 99.9% (3-log)
Cryptosporidium Zero 99% (2-log) (removal only)
Unfiltered Systems
Conventional and Direct
Filtration
Slow Sand, Diatomaceous or Alternative
Filtration
47
Residual Disinfectant Monitoring Requirements
PopulationEntrance to Distribution
SystemIn Distribution System
All Subpart H Systems
Cannot be < 0.2 mg/L for more than 4 hours1
Detectable in at least 95% of samples in a month for any 2 consecutive months
1 Residual monitored continuously. A state may allow systems serving 3,300 or fewer persons to take grab samples from 1-4 times per day, depending on system size.
Unfiltered Systems
Conventional and Direct
Filtration
Slow Sand, Diatomaceous or Alternative
Filtration
48
Residual Disinfectant Reporting Requirements
Report to state due within 10 days of the end of the following month.
Remember to include:
A calculation of the percent of distribution residual
samples that were undetectable
Lowest daily value for each day
The date and duration when residual
disinfectant was <0.2 mg/L
When state was notified of events where residual
disinfectant was <0.2 mg/L
Unfiltered Systems
Conventional and Direct
Filtration
Slow Sand, Diatomaceous or Alternative
Filtration
49
Additional Disinfectant Monitoring Requirements
Frequency In Distribution System
Daily Before or at the first customer: Temperature pH (if chlorine is used) Disinfectant contact time(s) at peak hourly flow Residual disinfectant concentration measurement(s) at
peak hourly flow used in the inactivation calculation(s)
Unfiltered Systems
50
Additional Disinfectant Reporting Requirements
Daily residual disinfectant concentration(s) and
disinfectant contact time(s) used for calculating the CT
value(s).
As soon as possible, but no later than the end of the next business day. Remember to include:
Instances where the residual disinfectant
level entering the distribution system
was < 0.2 mg/L
Unfiltered Systems
Report to state due within 10 days of the end of the following
month. Remember to include:
51
Quiz #1: Disinfectant Residual Example System:
• Takes 3 routine TCR samples
• Uses Surface Water
• Has a Conventional Filtration
In addition to taking one sample at the entry point to the distribution systems, what does this system need to do to comply with the SWTRs residual disinfectant monitoring requirements?
Conventional and Direct
Filtration
52
Quiz #1: Disinfectant Residual
Entry Point
= Sample Location
Conventional and Direct
Filtration
System needs to take:
3 disinfectant residual samples at the same time
and place as the TCR sample
40 CFR 141.74 (b)(6)(i)
53
Quiz #2: Unfiltered System Reporting Requirements
What does this system need to report in order to comply with the SWTRs residual disinfectant monitoring requirements?
1)Daily residual disinfectant concentration(s) & disinfectant contact time(s) used for calculating the CT value(s)
2)Lowest daily value for each day
3)The date/duration when residual disinfectant was <0.2 mg/L
4)When state was notified of events where residual disinfectant was <0.2 mg/L
5)A calculation of the percent of distribution residual samples that were undetectable
6)All of the aboveUnfiltered Systems
Example Systems: Unfiltered, Surface Water system that serves 12,000 people
54
Quiz #2: Unfiltered System Reporting Requirements
What does this system need to report in order to comply with the SWTRs residual disinfectant monitoring requirements?
6)All of the above
Lowest daily value for each day
The date and duration when
residual disinfectant was
<0.2 mg/L
When state was notified of events
where residual disinfectant was
<0.2 mg/L
A calculation of the percent of distribution residual
samples that were undetectable
Daily residual disinfectant concentration(s) and disinfectant contact time(s) used for calculating the CT value(s).
Unfiltered Systems
Example Systems: Unfiltered, Surface Water system that serves 12,000 people
55
Quiz #3: Filtered System Reporting Requirement
What does this system need to report in order to comply with the SWTRs residual disinfectant monitoring requirements?
1)Lowest daily value for each day
2)The date and duration when residual disinfectant was <0.2 mg/L
3)When state was notified of events where residual disinfectant was <0.2 mg/L
4)A calculation of the percent of distribution residual samples that were undetectable
5)All of the aboveSlow Sand, Diatomaceous or Alternative
Filtration
Example Systems: GWUDI systems that serves 4,500 people that uses slow sand filtration and measures HPC in lieu of distribution disinfectant residuals.
56
Quiz #3: Filtered System Reporting Requirement
What does this system need to report in order to comply with the SWTRs residual disinfectant monitoring requirements?
5)All of the above
Slow Sand, Diatomaceous or Alternative
Filtration
Lowest daily value for each day
The date and duration when
residual disinfectant was
<0.2 mg/L
When state was notified of events
where residual disinfectant was
<0.2 mg/L
A calculation of the percent of distribution residual
samples that were undetectable
Example Systems: GWUDI systems that serves 4,500 people that uses slow sand filtration and measures HPC in lieu of distribution disinfectant residuals.
How long have you worked with the surface water rules (base your response on the average in the room) 0-6 Months 7-12 Months 1-2 Years 2-4 Years 4+ Years
58
Questions
Please send your questions & comments via the web console located on your bottom right.
Q & A
59
Disinfection Profiling and Benchmarking
60
Disinfection Profiling and Benchmarking A “Snap-Shot” Ensures Microbial Protection 3-Step Process
1. Applicability Determination
2. Profiling
3. Benchmarking and Consultation
Slow Sand, Diatomaceous or Alternative
Filtration
Unfiltered Systems
Conventional and Direct Filtration
61
Disinfection Profiling and Benchmarking Applies to: all Subpart H
PWSs Profiling requirements vary
by system size
Disinfection benchmark must be calculated and State must be consulted if the system is considering:
• Changes to the point of disinfection
• Changes to the disinfecant(s) used
• Changes to the disinfection process
• Any other modification identified by the state.
Slow Sand, Diatomaceous or Alternative
Filtration
Unfiltered Systems
Conventional and Direct
Filtration
40 CFR 141.172 and 141.530
62
Why Develop a Disinfection Profile and Benchmark? A Regulatory Threshold to Be Achieved The Threshold Is Often Exceeded Assess Affects of Treatment Changes Upon Actual
Inactivation Consider:
• Positive and Negative Impacts
• Acute and Chronic Health Risks
• Alternatives Public Health Based Decision
Slow Sand, Diatomaceous or Alternative
Filtration
Unfiltered Systems
Conventional and Direct Filtration
63
To Distribution
Why Develop a Disinfection Profile & Benchmark?
Filters
Contact Basin
Flocculation Basins
Potential Chlorination Points
SedimentationBasin
Lake1
2
3
4
Slow Sand, Diatomaceous or Alternative
Filtration
Unfiltered Systems
Conventional and Direct Filtration
64
Month Week Log Inact. Giardia
Month Week Log Inact. Giardia
JAN 1 1.34 JULY 27 1.86 2 1.35 28 1.82 3 1.38 29 1.76 4 1.37 30 1.74
FEB 5 1.38 AUG 31 1.71 6 1.38 32 1.70 7 1.39 33 1.66 8 1.40 34 1.61
MARCH 9 1.40 SEP 35 1.60 10 1.40 36 1.55 11 1.41 37 1.56 12 1.42 38 1.52 13 1.43 39 1.51
APRIL 14 1.46 OCT 40 1.47 15 1.50 41 1.48 16 1.54 42 1.47 17 1.57 43 1.47
MAY 18 1.64 NOV 44 1.45 19 1.66 45 1.41 20 1.70 46 1.43 21 1.72 47 1.41
JUNE 22 1.74 DEC 48 1.40 23 1.77 49 1.40 24 1.79 50 1.40 25 1.82 51 1.40 26 1.81 52 1.37
04/19/23 Conventional and Direct Filtration
Example Disinfection Profile
0.000
0.200
0.400
0.600
0.800
1.000
1.200
1.400
0 4 8 12 16 20 24 28 32 36 40 44 48 52
Week Tested
Lo
g In
acti
vati
on
, Giardia
Log Inactivation
66
LT1ESWTR Profiler
www.LT1P.com
67
Disinfection Profile and Benchmark
“Lessons Learned in the Process”
Alexander Vanegas
City of Manassas
June 2005
68
EPA Sets Guidelines
The purpose of developing the disinfection profile and benchmark is to provide a basis for the water system and the state primacy agency to work together to assure that any changes in disinfection practices to meet new disinfection byproduct MCLs will not result in a significant reduction in the microbial protection provided by the system.
69
EPA Sets Guidelines
In order to determine if profiling was necessary, water utilities were to conduct four quarters of "Applicability Monitoring" for TTHMs and HAAs. If the TTHM or HAA annual averages from the applicability monitoring exceeded 64 ppb or 48 ppb, respectively, the water system needed to prepare a disinfection profile.
70
Crypto & Giardia Removal All surface water systems that serve more than l0,000
people and are required to filter must achieve at least:
• 2 log removal of Cryptosporidium or 99% removal based on treatment technique
• 3 log removal of Giardia lamblia or 99.9% removal/inactivation based on treatment technique.
• 4 log removal of viruses or 99.99% removal/inactivation based on treatment technique.
71
Timeline of Problems
January 2002 - TTHM & HAA MCL reduced from 100ppb -80ppb respectively to 80-60 ppb.
November 2002 - Manganese violation (0.05 mg/L) December 2002 - Exceeding TTHMs MCL and
difficulty meeting TOC removal December 2002 - Inverted application of Chlorine
from heavy Pre-CL 2 in Rapid Mix and low concentration in clearwell to low Pre-CL 2 in Rapid Mix and higher concentration in clearwell.
72
Timeline: Action Steps taken to Obviate the Situation January 2003 - Switched coagulant from Aluminum
Sulfate to Ferric Chloride to assist in TOC removal and reduce TTHMs.
October 2003 - Moved CL2 application point from rapid mix to pre-filter area after sedimentation basins.
January 2004 - Switched from Gaseous Chlorine to Sodium Hypochlorite
73
Timeline: Action Steps taken to Obviate the Situation September 2004 - Replaced GAC media
December 2004 - Lead & Copper exceeds limits requiring action. (15 ppb)
May 2005 - Switched to Ferric Sulfate.
74
January 2003—Switched to Ferric Chloride Switched from Alum Common trend in industry Assist with TOC removal and increased NOM
removal Implications
75
October 2003—Chlorine Application
Moved Chlorine Application Point Originally at Rapid Mix prior to Sedimentation New location prior to filters after sedimentation.
76
January 2004—Switch to NaOCL
Sodium hypochlorite, (NaOCl) offers an excellent alternative approach to disinfection. The active ingredient is the hypochlorite ion OCl—, which hydrolyzes to form hypochlorous acid (HOCl).
77
January 2004—Switch to NaOCL Often called liquid bleach, is considered to be the
second cheapest disinfectant after bulk liquid chlorine gas. Commercially available as a 12.5 percent solution, it offers most of the advantages of chlorine gas–as a disinfectant, oxidizing agent and residual disinfectant, yet it does not have transportation or storage hazards to the extent present with chlorine gas.
Impetus driven by Vulnerability Assessment & reduction of potential hazard in area of high development.
78
Disinfection Profile 2002Disinfection Profile
0.00
0.50
1.00
1.50
2.00
2.50
3.00
3.50
4.00
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2 21 2 2 2 2 2 2 2 2 3 31
Day of the Month
Inactivation Ratio Logs of Inactivation
79
Disinfection Profile 2003Disinfection Profile
0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
9.00
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2 21 2 2 2 2 2 2 2 2 3 31
Day of the Month
Inactivation Ratio Logs of Inactivation
80
Disinfection Profile 2005Disinfection Profile
0.00
2.00
4.00
6.00
8.00
10.00
12.00
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2 21 2 2 2 2 2 2 2 2 3 31
Day of the Month
Inactivation Ratio Logs of Inactivation
81
Comparison of Water Quality
Prior to Changes 2002 TTHMs - 97 ppb RAA HAA5 - 35 ppb RAA TOC removal
• 41% highest
After Changes 2004 TTHMs - 55 ppb RAA HAA5 - 30 ppb RAA TOC removal
• 64% highest
Is the person or persons responsible for implementing the surface water rules attending this training? Yes No Not Sure.
83
Questions
Please send your questions & comments via the web console located on your bottom right.
Q & A
84
Other Requirements
Conventional and Direct Filtration Systems
Systems using Slow Sand, Diatomaceous Earth or Alternative Filtration
Unfiltered Systems
85
Other Requirements
Sanitary Surveys
• Community Water Systems: Every 3 years
• Noncommunity Water Systems: Every 5 Years
Covered Finished Water Reservoirs/Water Storage Facilities
Certified Operator
Conventional and Direct
Filtration
Slow Sand, Diatomaceous or Alternative
Filtration
Unfiltered Systems
86
Filter Backwash Recycling Rule. (FBRR) Purpose: To improve public health protection by
assessing and changing, where needed, recycle practices for improved contaminant control, particularly microbial contaminants.
Applies to Subpart H conventional or direct filtration systems that:
• Recycle spent filter backwash, thickener supernatant, or liquids from dewaterting processes
Conventional and Direct
Filtration
87
FBRR Requirements
Return recycle flows through all unit processes at treatment system or alternative location approved by the states
Collecting and retaining recycle flow information
Completing all capital improvements associated with relocating recycle return location by June 8, 2006
Conventional and Direct
Filtration
88
PN Rule Requirements (Tier 1)
Exceedance of maximum turbidity level
• Conventional and direct filtration
• Slow sand, diatomaceous earth, and alternative filtration
• Unfiltered Waterborne disease outbreak
Unfiltered Systems
Slow Sand, Diatomaceous or Alternative
Filtration
Conventional and Direct
Filtration
89
PN Rule Requirements (Tier 1)
Tier 1: Notify the state within 24 hours of the violation!
• For turbidity, State will determine whether violation is Tier 1 or Tier 2
• Notify customers within 24 hours if violation is Tier 1
• Design communication to reach all users
• Send a copy to the state within 10 days of notifying customers
Unfiltered Systems
Slow Sand, Diatomaceous or Alternative
Filtration
Conventional and Direct
Filtration
90
Violations Requiring Tier 2 PN Turbidity violations
• Single exceedance – As determined by the state• 95th percentile exceedance
Failure to perform profiling Failure to consult with state prior to changing disinfection
practices Inactivation violations > 5 percent undetectable distribution residuals Failure to meet avoidance criteria Failure to recycle to an appropriate location (FBRR) Failure to complete capital improvements by required schedule
(FBRR)
Unfiltered Systems
Slow Sand, Diatomaceous or Alternative
Filtration
Conventional and Direct
Filtration
91
Notify customers within 30 days
Send a copy of PN to the state within 10 days of notifying customers
PN Rule Requirements (Tier 2)
Tier 2: Notify the state within 48 hours of the violation!
Unfiltered Systems
Slow Sand, Diatomaceous or Alternative
Filtration
Conventional and Direct
Filtration
92
PN Rule Requirements (Tier 3)
All Monitoring and Reporting Violations
Unfiltered Systems
Slow Sand, Diatomaceous or Alternative
Filtration
Conventional and Direct
Filtration
93
Notify customers within 12 months
Send a copy of PN to the state within 10 days of notifying customers
Notification may be included in CCR
PN Rule Requirements (Tier 3)
Unfiltered Systems
Slow Sand, Diatomaceous or Alternative
Filtration
Conventional and Direct
Filtration
94
Questions
Please send your questions & comments via the web console located on your bottom right.
Q & A
95
Turbidity Requirements
Conventional and Direct Filtration Systems
Systems using Slow Sand, Diatomaceous Earth or Alternative Filtration
Unfiltered Systems
96
Turbidity
Combined Filter Effluent (CFE)
Individual Filter Effluent (IFE)
Conventional and Direct
Filtration
Slow Sand, Diatomaceous or Alternative
Filtration
97
Conventional and Direct Filtration Systems
Conventional and Direct Filtration
98
CFE Requirements
Monitoring Requirement
Monitoring Frequency
Measurement
CFE 95% Value At least every 4 hours
< 0.3 NTU
Conventional and Direct Filtration
99
CFE Requirements
Monitoring Requirement
Monitoring Frequency
Measurement
CFE 95% Value At least every 4 hours
< 0.3 NTU
CFE Maximum Value
At least every 4 hours
1 NTU
Conventional and Direct
Filtration
100
CFE Reporting
Report to state due within 10 days of the end of the following month. Remember to include:
Percentage of CFE measurements <
95th % limit
Date and Value of any CFE
measurement that exceeded 1
NTU
Total number of CFE
measurements
Conventional and Direct
Filtration
101
CFE Exceedance Reporting(Systems serving at least 10,000 people)
Report to state as soon as possible, but no later than the end of the next
business day
Exceedance of 1 NTU
Conventional and Direct
Filtration
102
IFE Monitoring Requirements (Systems serving at least 10,000 people) IFE must be monitored continuously every 15
minutes
Conventional and Direct
Filtration
103
IFE Follow-up Steps (Systems serving at least 10,000 people)
Condition Action
1 2 consecutive measurements >0.5 NTU taken 15 minutes apart at the end of the first 4 hours of continuous filter operation after backwash/offline
Produce filter profile within 7 days (if cause is not known)
2 2 consecutive measurements >1.0 NTU taken 15 minutes apart
Produce filter profile within 7 days (if cause is not known)
3 2 consecutive measurements >1.0 NTU taken 15 minutes apart at the same filter for 3 months in a row
Conduct a filter self-assessment within 14 days
4 2 consecutive measurements >2.0 NTU taken 15 minutes apart at the same filter for 2 months in a row
Arrange for a CPE within 30 days and submit report within 90 days
Conventional and Direct
Filtration
104
IFE Reporting – Conditions 1, 2, and 3
Report to state due within 10 days of the end of the following month.
Remember to include:
Filter Number
Turbidity Value
Cause (if known) or report profile
was produced
Date
Conventional and Direct
Filtration
105
IFE Reporting – Condition 4
Report to state due within 10 days of the end of the
following month. Remember to include:
Filter Number
Turbidity Value
Date
Submit CPE Report
Schedule & conduct CPE.
Report to state due within 90 days
after exceedance:
Conventional and Direct
Filtration
106
IFE Monitoring Requirements (Systems serving fewer than 10,000 people) IFE must be monitored continuously every 15
minutes
Conventional and Direct
Filtration
107
IFE Follow-up Steps (Systems serving fewer than 10,000 people)
Conventional and Direct
Filtration
Condition Action
1 2 consecutive measurements >1.0 NTU taken 15 minutes apart
Reporting only
2 2 consecutive measurements >1.0 NTU taken 15 minutes apart at the same filter for 3 months in a row
Conduct a filter self-assessment within 14 days
3* 2 consecutive measurements >2.0 NTU taken 15 minutes apart at the same filter for 2 months in a row
Arrange for a CPE within 60 days and submit report within 120 days
* Exception if a CPE was done in the last 12 months
108
IFE Reporting – Condition 1
Report to state due within 10 days of the end of the following month.
Remember to include:
Filter Number
Turbidity Value
Cause (if known)
Date
Conventional and Direct
Filtration
109
IFE Reporting – Condition 2
Report to state due within 10 days of the end of the following month (or within 14
days of filter self-assessment being triggered if triggered in the last 4 days of
the month). Conduct filter self-assessment. Report:
Date the filter self-assessment was triggered
Date the filter self-assessment was completed
Conventional and Direct
Filtration
110
IFE Reporting – Condition 3
Report to State due within 10 days of the end of the following month.
Schedule & Conduct CPE. Remember to
include:
Date CPE was triggered
Submit CPE Report
CPE report to State due within 120 days after exceedance:
Conventional and Direct
Filtration
111
Case Studies: Great View Filtered Surface Water System, Serving 15,000
People, Using Direct Filtration
• Where, when, & how many CFE samples should this system take?
• What is the limit for the CFE 95th% value?
• What is the system required to report to the state within 10 days?
• Where & how many IFE samples should this system take?
• Two consecutive IFE measurements are >1.0 NTU What is the system required to do?
Case Study
Where, when, & how many CFE samples should this system take? One per year at the source Five samples per month in the distribution system At least one sample every 4 hours from the combined
filter effluent
113
Answer
Where, when, & how many CFE samples should this system take?
• At least one sample every 4 hours from the combined filter effluent
Direct Filtration System, serving
15,000
Case Study
What is the limit for the CFE 95th% value?
1.2 mg/L 1.0 NTU <= 0.3 NTU None of the above
115
Answer
What is the limit for the CFE 95th% value?
• <= 0.3 NTU
Direct Filtration System, serving
15,000
Case Study
What is the system required to report to the state within 10 days? Percentage of CFE measurements <= 95th% limit Date and value of any CFE measurement that
exceeded 1 NTU Total number of CFE measurements All of the above
117
Answer
What is the system required to report to the state within 10 days?
• All of the above
Direct Filtration System, serving
15,000
Case Study
Where & how many IFE samples should this system take? 1 sample at the entry point to the distribution system 2 samples in the source water Continuously monitor every 15 minutes from the
individual filter effluent At least every 4 hours at the entry point to the
distribution system
119
Answer
Where & how many IFE samples should this system take?
• Continuously monitor every 15 minutes from the individual filter effluent
Direct Filtration System, serving
15,000
Case Study
Two consecutive IFE measurements are >1.0 NTU. What is the system required to do? If the cause cannot be determined, produce a filter
profile within 7 days Report filter number, turbidity value(s) and date by
the 10th of the following month Report the cause, or report that a filter profile has
been completed, by the 10th of the following month, All of the above
121
Answer
Two consecutive measurements are >1.0 NTU. What is the system required to do?
• All of the above.
Direct Filtration System, serving
15,000
Case Study
122
Questions
Please send your questions & comments via the web console located on your bottom right.
Q & A
123
Systems using Slow Sand, Diatomaceous Earth or Alternative Filtration
Slow Sand, Diatomaceous or
Alternative Filtration
124
CFE Requirements
Monitoring Requirement
Monitoring Frequency
Measurement
CFE 95% Value At least every 4 hours
< 1 NTU
Slow Sand, Diatomaceous or Alternative
Filtration
125
CFE Requirements
Monitoring Requirement
Monitoring Frequency
Measurement
CFE 95% Value At least every 4 hours
< 1 NTU
CFE Maximum Value
At least every 4 hours
5 NTU
Slow Sand, Diatomaceous or Alternative
Filtration
126
CFE Reporting
Report to state due within 10 days of the end of the following month. Remember to
include:
Total number of monthly
measurements
Number and percent of monthly measurements less then or equal to designated
95th percentile turbidity limits
Date and value exceeding 5 NTU for slow sand and
diatomaceous earth filtration or maximum level set by the state for alternative filtration
Slow Sand, Diatomaceous or Alternative
Filtration
127
CFE Exceedance Reporting
Report to state as soon as possible, but no later than the end of the next business day :
Exceedance of 5.0 NTU for slow sand and diatomaceous earth filtration or maximum level set by the state for
alternative filtrationSlow Sand,
Diatomaceous or Alternative
Filtration
128
Case Studies: Plain Valley Filtered GWUDI System, Serving 300 People, Using
Slow Sand Filtration
• What is the reduced monitoring frequency that the state can set for this system?
• What is the maximum CFE limit?
• What is the system required to report to the state within 10 days?
• What are the removal/inactivation requirements for Viruses, Giardia Lamblia, and Cryptosporidium for this system?
• How many IFE samples should this system take?Case Study
What is the reduced monitoring frequency that the state can set for this system? At least every 8 hours One sample per day Continuous monitoring every 2 hours Four samples per day
130
Answer
What is the reduced monitoring frequency that the state can set for this system?
• One sample per day
Case Study
GWUDI System, serving 300 using
slow sand filtration
What is the maximum CFE limit?
<= 1 NTU 5 NTU <= 0.3 NTU None of the above
132
Answer
What is the maximum CFE limit?
• 5 NTU
Case Study
GWUDI System, serving 300 using
slow sand filtration
What is the system required to report to the state within 10 days? Total number of monthly measurements Number and percent less than or equal to designated
95% turbidity limits Date and value exceeding 5 NTU All of the above
134
Answer
What is the system required to report to the state within 10 days?
• All of the above
Case Study
GWUDI System, serving 300 using
slow sand filtration
What are the removal/inactivation requirements for Viruses, Giardia Lamblia, and Cryptosporidium for this system? Viruses - 4-log removal/inactivation, Giardia
Lamblia - 3-log removal/inactivation, Cryptosporidium - 2-log removal
Viruses - 2-log removal/inactivation, Giardia Lamblia - 2-log removal/inactivation, Cryptosporidium - 3-log removal
Viruses - 3-log removal/inactivation, Giardia Lamblia - 4-log removal/inactivation, Cryptosporidium - 4-log removal
136
Answer
What are the removal/inactivation requirements for Viruses, Giardia Lamblia, and Cryptosporidium for this system?
• Viruses - 4-log removal/inactivation, Giardia Lamblia - 3-log removal/inactivation, Cryptosporidium - 2-log removal
Case Study
GWUDI System, serving 300 using
slow sand filtration
How many IFE samples should this system take? At least every 4 hours Continuous monitoring every 15 minutes Not required Once per day
138
Answer
How many IFE samples should this system take?
• Not required.
Case Study
GWUDI System, serving 300 using
slow sand filtration
139
Unfiltered Systems
Unfiltered Systems
140
Filtration Avoidance Criteria
Source Water Conditions
• Turbidity
• Microbial quality Inactivation and Disinfectant Residual Watershed Control and Inspection
Unfiltered Systems
141
Source Water Conditions (Turbidity)
Requirement Frequency Measurement
Source Water Samples
At least every 4 hours
< 5 NTU on two consecutive days
Unfiltered Systems
142
Source Water Conditions (Microbial Quality)
Requirement Frequency Measurement
Fecal coliform
1 – 5 samples per week depending on system size and every day the turbidity of the source water exceeds 1 NTU
< 20/100 mL
And/Or
Total coliform
1 – 5 samples per week depending on system size and every day the turbidity of the source water exceeds 1 NTU
< 100/100 mL
Unfiltered Systems
143
Reporting Requirements
Report to state within 24 hours.
Turbidity exceedances of 5
NTU
Waterborne disease
outbreaks
Unfiltered Systems
144
Upcoming Regulations
Expected final in December 2005
• Stage 2 DBPR
• LT2ESWTR
Additional Resources
145
LT2ESWTR Preview Objective: Risk-based targeting approach to reduce exposure
to Cryptosporidium in public water systems.
• Target filtered systems with high source water Cryptosporidium levels where 99% (2-log) removal is not sufficient treatment
• Target all unfiltered systems, which currently provide no treatment
Components of LT2ESWTR:
• Filtered systems assigned to different “risk bins” based on results of source water Cryptosporidium monitoring
Additional Cryptosporidium treatment based on bin classification “Microbial Toolbox” of options – flexibility in meeting
additional treatment requirements
146
LT2ESWTR Preview
Additional LT2ESWTR requirements:
• Specific requirements for uncovered finished water reservoirs and unfiltered systems.
• Second round of monitoring 6 years following initial bin assignment.
• Disinfection profiling and benchmarking.
147
Evaluation Form – Available on the web at:
• http://yosemite.epa.gov/ogwdw/ogwdwsurvey.nsf/surveyhome?openform
• Enter code: survey07 Please email [email protected] if
you have questions
Join us for Data Verification Webcast Training
Wednesday, July 27, 2005, 2 – 4 PM
Join us for Data Verification Webcast Training
Wednesday, July 27, 2005, 2 – 4 PMDon’t Forget
148
Questions?
Please send your questions & comments via the web console located on your bottom right.
Q & A
149
Additional Resources
150
Webcast Materials
Drinking Water Academy Web site: www.epa.gov/safewater/dwa.html
• Webcast Presentation Slides
• Written Q&A from Webcast Will Be Emailed To All Registered Participants
Additional Resources
151
Additional Resources
Quick Reference Guides:
• IESWTR (EPA 816-F-01-011)
• LT1ESWTR (EPA 816-F-02-001)
• FBRR (EPA 816-F-01-019) Technical guidance documents:
• Alternative Disinfectants and Oxidants Guidance Manual (EPA 815-R-99-014)
• Disinfection Profiling and Benchmarking Guidance Manual (EPA 815-R-99-013)
• Enhanced Coagulation and Enhanced Precipitative Softening Guidance Manual (EPA 815-R-99-010)Additional
Resources
152
Additional Resources
Technical guidance documents (continued):
• Guidance Manual for Compliance with the Interim Enhanced Surface Water Treatment Rule: Turbidity Provisions (EPA 815-R-99-010)
• Guidance Manual for Conducting Sanitary Surveys of Public Water Systems; Surface Water and Ground Water Under the Direct Influence (GWUDI) (EPA 815-R-99-016)
• M/DBP Simultaneous Compliance Manual (EPA-815-R-99-015)
• Uncovered Finished Water Reservoirs Guidance Manual (EPA 815-R-99-011)
Additional Resources
153
Additional Resources
Technical guidance documents (continued):
• Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR) Implementation Turbidity Provisions - Technical Guidance Manual (EPA 816-R-04-007)
• Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR) Disinfection Profiling and Benchmarking Technical Guidance Manual (EPA 816-R-03-004)
• Filter Backwash Recycling Rule Technical Guidance Manual (EPA 816-R-02-014)
• Technical Fact Sheet: Final Filter Backwash Recycling Rule (EPA 815-F-01-001)
Additional Resources
154
Additional Resources Implementation guidance documents:
• IESWTR Final Implementation Guidance (EPA 816-R-01-011)
• LT1 Final Implementation Guidance (EPA 816-R-04-008)
• FBRR Final Implementation Guidance (EPA 816-R-04-006)
• IESWTR Plain English Guidance (EPA 816-R-01-014)
• Profiling and Benchmarking Fact Sheet (EPA 816-F-98-017b)
• IESWTR Fact Sheet (EPA 816-F-01-013)
Additional Resources
155
EPA Resources Available
All documents available through
• EPA’s Web site http://www.epa.gov/safewater/
OR
• By calling the Safe Drinking Water Hotline 1-800-426-4791
Additional Resources
156
For More Questions
Send Your State’s SWTRs Questions or Situations to:
• SWTRs Questions: Call your EPA Regional Office or Ed Moriarty, US EPA HQ 202-564-3864
Additional Resources
157
Next Webcast: Data Verifications
July 27, 2005, 2 – 4 PM (EST)
• For State Staff Only Overview of the EPA Headquarters-sponsored DV
process Example of process using TCR and Stage 1 DBPR as
examples
• Send your DV questions via email to: [email protected]
Additional Resources
158
Webcast Series See Handout or DWA Calendar for Upcoming 2005
Webcasts
• http://www.epa.gov/safewater/dwa/calendar.html Future Webcasts will:
• Cover a Variety of Subjects and Rules
• Be Held Last Wednesday of the Month from 2-4 PM (Eastern Time)
• Have the Same Registration Process as for SWTRs
• Will Open for Registration Six Weeks Prior to Each Webcast
Additional Resources