Stage 2 Disinfectants and Disinfection Byproducts Rule (DBPR) and Consecutive System In-Depth Analysis: U.S. Environmental Protection Agency Final Report

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The United States Environmental Protection Agency (“EPA”) issued a July 2019 report titled:

Stage 2 Disinfectants and Disinfection Byproducts Rule (DBPR) and Consecutive System In-Depth Analysis (“Report”)

The Report is a part of an analysis of implementation of Safe Drinking Water Act rules that EPA has been conducting.

The Report focuses on the Stage 2 Disinfectants and Disinfection Byproducts Rule (“DBPR”). It is a collaborative effort between EPA and the state drinking water primacy agencies. Their interest is driven by the fact that the Safe Drinking Water Act National Primary Drinking Water Regulation with the largest number of community water systems in violation involves the Stage 2 DBPR rule.

The chapters of the Report include:

  • Stage 2 DBPR and Consecutive CWS Challenges
  • National Data Analysis of Stage 2 DBPR Compliance
  • Challenges, Lessons Learned, and Best Practices
  • Approaches to Reduce DBPs through Optimization

Note that the third chapter includes state best practices incorporating feedback from 32 states provided by the Association of State Drinking Water Administrators. It is organized around the following described implementation challenges, which include:

  1. What approaches can a CWS take to reduce disinfection byproduct (DBP) formation?
  2. What are the best practices for distribution system sampling and analytical methods?
  3. What approaches can be used to facilitate coordination between a wholesale and consecutive system?
  4. What capacity development tools can be used to address DBP issues?
  5. How can Drinking Water State Revolving Fund (DWSRF) resources be used to assist systems with DBP violations?
  6. How can state enforcement be used to help systems return to compliance?
  7. What approaches can be used to enhance operator training on DBP compliance issues?

A copy of the Report can be downloaded here.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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