Trident Park-2019 DDBPR.pdf

CONTRACT: N62470-14-D-9022

DELIVERY ORDER: N4008518F6644

July 2019

Draft

NAVAL SUBMARINE BASE NEW LONDON,

CONNECTICUT

NAVFAC MID-ATLANTIC

2019 DISINFECTANTS AND DISINFECTION BYPRODUCTS

RULE DRINKING WATER MONITORING PLAN UPDATE

TRIDENT PARK

DRAFT

2019 DISINFECTANTS AND DISINFECTION

BYPRODUCTS RULE DRINKING WATER

MONITORING PLAN UPDATE – TRIDENT PARK

NAVAL SUBMARINE BASE NEW LONDON,

CONNECTICUT

Prepared For:

Taylor Jones

NAVFAC MIDLANT

9742 MARYLAND AVE

NORFOLK, VA 23511-2095

CONTRACT: N62470-14-D-9022

DELIVERY ORDER: N4008518F6644

July 2019

AH/BC Navy JV, LLC.

11837 Rock Landing Drive, Suite 300 Newport News, Virginia 23606

2019 D/DBPR DRINKING WATER MONITORING PLAN UPDATE

SUBASENLON-TRIDENT PARK

NAVAL SUBMARINE BASE NEW LONDON, CT TABLE OF CONTENTS

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1. INTRODUCTION ................................................................................... 1-1

1.1 PURPOSE ................................................................................................1-3

1.2 SITE SPECIFIC SAMPLING PLAN COMPONENTS ...........................................1-4

1.3 PLAN ORGANIZATION ................................................................................1-5

2. SUBASENLON TRIDENT PARK WATER SYSTEM ............................ 2-1

2.1 SERVICE CONNECTIONS ...........................................................................2-2

3. REGULATORY REQUIREMENTS ........................................................ 3-1

4. DISINFECTANT RESIDUAL SAMPLING AND MONITORING ............ 4-1

5. SAMPLING AND SAMPLE ANALYSIS PROCEDURES ...................... 5-1

5.1 TRAINING AND CERTIFICATION REQUIREMENTS ..........................................5-1

5.2 SAMPLE COLLECTION PROCEDURES ..........................................................5-2

6. STAGE 2 D/DBPR SAMPLING FREQUENCY AND SAMPLING SITE

SELECTION .......................................................................................... 6-1

6.1 SAMPLING FREQUENCY ............................................................................6-1

6.2 SAMPLING LOCATIONS SELECTION JUSTIFICATION ......................................6-3

7. CALCULATING THE LRAA AND OEL ................................................. 7-1

7.1 CALCULATING LOCATIONAL RUNNING ANNUAL AVERAGE ............................7-1

7.2 CALCULATING OPERATIONAL EVALUATION LEVEL (OEL) .............................7-3

8. PUBLIC NOTIFICATION ....................................................................... 8-1

9. REFERENCES ...................................................................................... 9-1

APPENDICES

A. STATEMENT OF WORK

B. STATE OF CONNECTICUT STAGE 2 DBPR FACT SHEET AND COMPLIANCE

MONITORING PLAN

• B1 – State of Connecticut Stage 2 DBPR Fact Sheet Template

• B2 – Compliance Monitoring Plan Template Form

• B3 – Stage 2 D/DBPR Monitoring Plan Instructions

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C. STATE OF CONNECTICUT CERTIFIED LABORATORIES LIST AND EXAMPLE

CHAIN OF CUSTODY FORM

• C1 – State of Connecticut In-state Approved Laboratories Certified to Test Drinking Water

• C2 – Example Chain of Custody Form

D. D/DBPR PUBLIC NOTIFICATION TEMPLATE

• D1 – Notification of important information about drinking water (DBP precur-sors)

• D2 – Notice for SUBASENLON system’s water consumers

• D3 – Instructions for Stage 2 DBPR TTHM MCL Violation Notice

• D4 – Instructions for Stage 2 DBPR HAA5 MCL Violation Notice

• D5 – Instructions for MRDL Notice

• D6 – Instructions for Monitoring Violations Annual Notice

TABLES

TABLE PAGE

Table 1-1 SUBASENLON Water System Information ..........................................1-4 Table 2-1 SUBASENLON Trident Park Distribution System Pipe Material and Length ..........................................................................................2-2 Table 2-2 GU Service Connections to Trident Park Water System ......................2-2 Table 5-1 Sampling Requirements of TTHM and HAA5 Analyses .......................5-4 Table 6-1 Monitoring for Stage 2 D/DBPR ...........................................................6-2 Table 6-2 SUBASENLON Trident Park Water System DBP Routine Monitoring

Frequency ...........................................................................................6-2 Table 6-3 Stage 2 D/DBPR Regulated Maximum Contaminant Level ..................6-3 Table 6-4 Trident Park - Stage 2 D/DBPR Compliance Monitoring Locations ......6-5 Table 7-1 Example of LRAA Calculation ..............................................................7-2 Table 8-1 Stage 2 D/DBPR Public Notification Required for Violations and

Other Situations ...................................................................................8-2

FIGURES

FIGURE PAGE

Figure 1-1 SUBASENLON Location and Vicinity Map ...........................................1-2 Figure 6-1 Stage 2 D/DBPR Sampling Location Map ............................................6-7 Figure 8-1 Public Notification Procedure ...............................................................8-4

NAVAL SUBMARINE BASE NEW LONDON, CT ACRONYMS AND ABBREVIATIONS

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ACRONYMS AND ABBREVIATIONS

AWWA American Water Works Association

CFR Code of Federal Regulations

COC chain of custody

CT Connecticut

CWS community water system

DBP disinfection byproducts

D/DBPR Disinfectants and Disinfection Byproducts Rule

EPA United States Environmental Protection Agency

FR Federal Record

GU Groton Utilities

HAA5 five haloacetic acids

IDSE initial distribution system evaluation

LRAA locational running annual average

MCL maximum contaminant level

MRDL maximum residual disinfectant level

NAVFAC MIDLANT Naval Facilities Engineering Command – Mid-Atlantic

NPDWR National Primary Drinking Water Regulations

OEL Operational Evaluation Level

OPNAVINST Office of the Chief of Naval Operations Instruction

PM Drinking Water Program Manager

PTFE polytetrafluoroethylene

PWS public water system

RAA running annual average

RCSA Regulations of Connecticut State Agencies

SDWA Safe Drinking Water Act

SDWIS The Safe Drinking Water Information System

SUBASENLON Naval Submarine Base New London

TT treatment technique

TTHM total trihalomethanes

US United States

VOC volatile organic compound

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SUBASENLON-TRIDENT PARK SECTION 1

NAVAL SUBMARINE BASE NEW LONDON, CT INTRODUCTION

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1. INTRODUCTION

Originally founded in 1868, the Naval Submarine Base New London (SUBASENLON) is one of the oldest Navy bases still in use today. Located in the town of Groton, Con-necticut (CT), it is the Navy’s first submarine base and the “Home of the Submarine

Force.” In 1916, many United States (US) submarines used the base as a homeport and a place for repair, resupply, and sailors’ rest and recuperation before returning to the front of World War I. SUBASENLON is located in the county of New London, CT, along the Thames River. The installation occupies more than 687 acres for

SUBASENLON Main Base and over 530 acres for housing areas, with more than 1,500

Public/Private Venture family housing units.

This Disinfectants and Disinfection Byproducts Rule (D/DBPR) monitoring plan covers the US Navy drinking water system at the SUBASENLON, Trident Park housing area.

Separate sampling plans for other sites maintained by the SUBASENLON Public Work

Department (PWD) are contained in separate documents for each of the following ar-eas:

1. Main Base

2. Nautilus Park

3. Polaris Park

4. Conning Towers

The potable water system in the housing portion of Dolphin Gardens is owned and maintained by the City of Groton, as was indicated in an agreement between Balfour

Beatty Communities and the City of Groton Utilities (GU) Department of Utilities dated

August 22, 2008. Also, the potable water system in Nautilus Park 3 north of Gun-gywamp Road is owned and maintained by the City of Groton based on an agreement between the two aforementioned parties dated February 13, 2007. Therefore, the parts of the system operated by GU in these areas are not included in the scope of this task order (see Appendix A for Statement of Work (SOW)).

Figure 1-1 is a location map that shows the SUBASENLON Trident Park and other

SUBASENLON Areas.

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Figure 1-1 SUBASENLON Location and Vicinity Map

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SUBASENLON Trident Park is not a state-recognized Public Water System (PWS). Its population includes active duty, reserve and civilian personnel, as well as military fam-ilies. Under the Safe Drinking Water Act (SDWA), the state or primacy agency is the authority that enforces the SDWA requirements including approvals, monitoring, and reporting compliance. In addition to Navy drinking water requirements, the Drinking

Water Program Manager (PM) at Naval Facilities Engineering Command (NAVFAC)

Mid-Atlantic (MIDLANT) serves as the SDWA primacy agency entity.

1.1 PURPOSE

As part of the ongoing effort to ensure the consistent and continuous delivery of safe potable water, as required by the Navy Command, NAVFAC MIDLANT, in cooperation with the Environmental Division (EV) at the SUBASENLON, contracted AH/BC Navy

JV, LLC to update the drinking water monitoring plan of the SUBASENLON Trident

Park water system. This sampling plan reflects the SUBASENLON Trident Park com-pliance with the D/DBPR requirements.

The D/DBPR was promulgated in two (2) stages. The Stage 1 D/DBPR reduced con-sumer drinking water exposure to disinfection byproducts (DBP). The Stage 2 D/DBPR strengthened public health protection by tightening compliance monitoring require-ments for total trihalomethanes (TTHM) and five haloacetic acids (HAA5)1. The Stage

2 D/DBPR targeted public water systems (PWSs) with the greatest risk of the presence of disinfectants and their by-products in the distributed water. The SUBASENLON Tri-dent Park does not add disinfectant to the GU purchased water. Therefore, this moni-toring plan is focused on the DBP that form downstream of the GU interconnections.

This D/DBPR sampling plan complies with Navy regulations i.e., Office of the Chief of

Naval Operations Instruction (OPNAVINST) 5090.1D2, and EPA 815-R-09-017, March

20103 and conforms with common drinking water industry standards and practices, 1United States Environmental Protection Agency (EPA). August 2010. Comprehensive Disinfectants and Disinfection Byproducts Rules (Stage 1 and Stage 2): Quick Reference Guide. EPA 816-F-10-080.

http://www.epa.gov/ogwdw/mdbp/qrg_st1.pdf. (Internet accessed: 07.02.2019) 2 Office of the Chief of Naval Operations Instruction (OPNAVINST) 5090.1D, 10 Jan 2014.

3 EPA. March 2010. Stage 2 Disinfectants and Disinfection Byproducts Rule Consecutive Systems Guid-ance Manual, EPA 815-R-09-017. Internet accessed: 7/17/2019.

http://www.epa.gov/ogwdw/mdbp/qrg_st1.pdf

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This work was performed under Contract Number: N62470-14-D-9022 and Delivery

Order N4008518F6644 as indicated in the SOW in Appendix A.

1.2 SITE SPECIFIC SAMPLING PLAN COMPONENTS

This D/DBPR sampling plan for SUBASENLON Trident Park considers the following components:

1. Water System Classification: Table 1-1 describes the SUBASENLON Trident

Park water system classification.

Table 1-1 SUBASENLON Water System Information

Water System Classification Summary

Component Description

System Name SUBASENLON Trident Park

PWS Identification (ID) Number

Not applicable

System Type Inactive (state exempt) consecutive Community Water System

(CWS)

Water Sources List

- including facility Safe Drinking Water ID*

Master meter customer of GU - PWSID: CT0590011 (GU’s water is supplied from a series of five interconnected reser-voirs covering a watershed of 16 square miles, and also includes three wells. Four reservoirs – Morgan, Ledyard, Poheganut, and Smith Lake - flow into Poquonock, their terminal reservoir)

System’s Owner/Oper-ator Contact Infor-mation

Mike Brown, Environmental Division Director

PWD ‐ SUBASENLON

Naval Submarine Base New London Box 44 Groton, CT 06349- Phone: (860) 694-3976, Cell: (860) 287‐7268 Email: michael.brown13@navy.mil

Total Number of Ser-vice Connections:

Population Served ~700

Wholesaler (Water Purveyor)

Groton Utilities (PWSID: CT0590011)

Groton Utilities, 295 Meridian Street, Groton, CT 06340

T: (860) 446-4000, F: (860) 446-4098

Prepared Date Plan July 2019

Plan Point of Contact Rich Massad (SUBASENLON PWD EV: (860) 694-5140

*As reported under The Safe Drinking Water Information System (SDWIS) https://www3.epa.gov/en-viro/facts/sdwis/search.html mailto:michael.brown13@navy.mil https://www3.epa.gov/enviro/facts/sdwis/search.html https://www3.epa.gov/enviro/facts/sdwis/search.html

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2. Distribution System Map indicates water system components (i.e., layout of dis-tribution mains, city interconnections, and routine sampling sites).

3. Minimum Number of Routine Samples required per monitoring period based on the population served in accordance with 40 Code of Federal Regulations

(CFR) 141.21(a)(2) and (a)(3) for SUBASENLON Trident Park.

4. Frequency of Sample Collection at each sample site per monitoring period and a sample collection schedule.

Note: In accordance with 40 CFR 141.21(a)(4), the water system is expected to collect samples at regular time intervals throughout the month.

5. Appropriate Sampling Sites within the distribution network that characterize the areas of the distribution system with different water ages, having cross-connec-tion hazards, representing low or no chlorine residuals, and/or representing wa-ter supply to critical/sensitive facilities.

Note: Samples should not be collected from fire hydrants, faucets that point upward (i.e., drinking water fountains), faucets that are corroded or have leaking packing material, swivel type faucets, faucets with threads on the inside of their spouts, faucets with aerators or screens (aerators or screens should be removed with care), automatic faucets, faucets that are close to or below ground level, faucets that are dirty or surrounded by excessive foliage, or taps that are dirty, corroded, or leaking.

Samples should not be collected from a hose or other faucet attachment.

1.3 PLAN ORGANIZATION

Section 2 of this document summarizes the SUBASENLON Trident Park water system classification and distribution network information. Section 3 describes the regulatory drivers for the plan, as well as applicable monitoring requirements under OPNAVINST

5090.1D Navy policy and the SDWA 40 CFR §141.21. Section 4 outlines the disinfect-ant residual sampling and monitoring. Section 5 presents the sampling and sample analysis procedures. Section 6 details the Stage 2 D/DBPR sampling frequency and sampling site selection. Section 7 presents the method of calculating the LRAA and

OEL. Section 8 presents Public Notification (PN) procedures as they apply to

SUBASENLON Trident Park water system and Section 9 provides a list of references cited in this plan.

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SUBASENLON-TRIDENT PARK SECTION 2

NAVAL SUBMARINE BASE NEW LONDON, CT SUBASENLON TRIDENT PARK WATER SYSTEM

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2. SUBASENLON TRIDENT PARK WATER SYSTEM

This section identifies the main features of the SUBASENLON Trident Park water sys-tem.

The SUBASENLON Trident Park water system purchases treated water from the GU

Water Treatment Plant (WTP), a private entity that supplies water to the city and other towns and industrial facilities in the area. The SUBASENLON Trident Park provides water to the public, but does not sell water4, is not a carrier, and does not provide treatment (as in additional filtration or by adding disinfectant). SUBASENLON Trident

Park water system is not a licensed water system in the State of Connecticut (CT) and therefore it is not subject to the Stage 2 D/DBPR compliance requirements. The

SUBASENLON Trident Park water system is required by Navy command instructions, at a minimum, to comply with monitoring requirements pertaining to those contaminants that could be contributed by the water distribution system downstream of the intercon-nection(s) to the primary supplier. The State of Connecticut Department of Public

Health (DPH-CT) September 13, 1993 letter confirmed SUBASENLON’s status as a service connection or a Master Meter customer to GU and therefore, exempt from the requirements of the SDWA. Consequently, the DPH-CT removed SUBASENLON from both the state and federal inventories of PWSs. Under the Navy water system certifi-cation program, the SUBASENLON Trident Park system is classified as a consecutive

CWS.

4 If any of the SUBASENLON water systems sells water, that system becomes a regulated PWS subject to the SDWA and CT State primacy regulations. OPNAVINST 5090.1D Section 21-3.3 (b), states the following: ”There is no definition of "selling water" in SDWA however, EPA’s “Operator Certification Guide-lines Implementation Guidance” January 2000 defines selling water as follows: "A distributor of water for human consumption "sells" water within the meaning of the Act if it charges consumers for the water as a separate item or bills separately for the water it provides (House Report No. 93-1185). Conversely, if the entity includes charges for water in the rental fee, then it is not selling water within the context of the Act."

The Navy does not consider reimbursement for distribution system maintenance costs and water from one federal entity to another as selling water; this is merely an internal allocation of funds within the executive branch. The EPA definition above would apply to non-federal consumers including banks, credit unions, private companies, and restaurants to which Navy distributes water.

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The SUBASENLON Trident Park housing area has a population of approximately 700 and operates a water distribution system that provides water for human consumption to the base population through pipes and other constructed storage and conveyances.

Table 2-1 summarizes the SUBASENLON Trident Park distribution system piping length by material type.

Table 2-1 SUBASENLON Trident Park Distribution System Pipe Material and Length

Miles of Distribution Pipe of Each Material (km) Best Estimate for

Construction Year(s) Copper Ductile Iron Total

1.36 (2.2) 2.04 (3.3) 3.4 (5.4) 1982

2.1 SERVICE CONNECTIONS

The DPH-CT classifies SUBASENLON Trident Park water system as a service con-nection to GU and does not regulate it as a PWS, consecutive or otherwise, nor require the system to monitor water quality. The SUBASENLON Trident Park water distribution system receives potable water from GU through one (1) service connection, as sum-marized in Table 2-2.

Table 2-2 GU Service Connections to Trident Park Water System

SUBASENLON

Water System

Total Number of Ser-vice Connections

Location

Trident Park 1 One (1) at Briar Hill Road

The GU WTP source water includes a series of five interconnected reservoirs covering a watershed of 16 square miles (four reservoirs – Morgan, Ledyard, Poheganut and

Smith - flow into Poquonock, the final terminal reservoir), and three backup wells. GU owns and maintains the water meters and the Navy owns the pits (structure, pipe, and cover).

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GU has no notices of violation of the SDWA for at least the last 10 years. Therefore, any water quality issues experienced by SUBASENLON Trident Park water system customers related to pipe or fittings corrosion, microbial contamination, or lead and copper in drinking water most probably originate within its distribution system.

The system includes a pumping station, and ground and elevated water storage tanks.

The potable water distribution system consists of approximately 3.4 miles of distribution piping of up to 12 in diameter. The system includes a 300,000-gallon water storage tank and a water pump station. The original distribution system was installed in 1982.

Pipe materials include approximately 60% ductile iron and 40% copper. The system is a combined potable and fire protection system.

The Navy requires SUBASENLON Trident Park to monitor contaminants (e.g., DBP) that could be contributed by the water distribution system downstream of the intercon-nection(s) to the primary supplier regardless of a state variance or exemption from reg-ulatory monitoring requirements. This D/DBPR sampling plan provides a site-specific sampling plan for SUBASENLON Trident Park. This plan requires periodic updates based on sampling site availability and base population changes. Appendix B includes the CT Stage 2 D/DBPR fact sheet and compliance monitoring plan form (provided here for information in case the system becomes regulated).

The PM NAVFAC MIDLANT serves as the primacy agency entity where, under the

SDWA, approval or compliance with Navy requirements and reporting is required.

Therefore, SUBASENLON Trident Park must comply with the monitoring requirements of D/DBPR. As stipulated in the OPNAVINST 5090.1D, Navy water systems, at a min-imum, must comply with the Stage 2 D/DBPR. This monitoring is required regardless of a state variance or exemption from regulatory monitoring requirements. This

SUBASENLON Trident Park Stage 2 D/DBPR monitoring plan will require periodic up-dates based on sampling site availability and population changes.

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SUBASENLON-TRIDENT PARK SECTION 3

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3. REGULATORY REQUIREMENTS

This section summarizes the regulatory requirements applicable to the drinking water systems at SUBASENLON Trident Park. Under the SDWA, consecutive PWSs are not generally subject to the monitoring requirements of the SDWA if they satisfy all of the following criteria specified in the National Primary Drinking Water Regulations

(NPDWR) 40 CFR 141.3:

• The PWS consists of only distribution and storage facilities and does not have any collection or treatment facilities

• The PWS obtains all its water from, but is not owned or operated by, a PWS to which the regulations apply

• The PWS does not sell water to any persons

• The PWS is not a carrier that conveys passengers in interstate commerce

All Navy systems, including unregulated consecutive systems, must develop a drinking water D/DBPR sampling plan and consumer notification, in compliance with

OPNAVINST 5090.1D5 requirements.

The SDWA and the OPNAVINST 5090.1D (10 January 2014), classify the

SUBASENLON Trident Park water system as a PWS and a community water system

(CWS). As a state-exempt consecutive water system, SUBASENLON Trident Park is not subject to the Regulations of Connecticut State Agencies (RCSA) Section 19-13-

B102 (Standards for quality of public drinking water). The CT Department of Public

Health Drinking Water Section is the state primacy agency in charge of enforcing the

SDWA regulations. In accordance with the SDWA 1996 amendments, EPA developed the Stage 1 D/DBPR6 (December 1998) to mitigate health risks caused by disinfectants and DBP in drinking water. The Stage 2 D/DBPR (January 2006) built upon Stage 1

D/DBPR to provide protection measures beyond those required by Stage 1 D/DBPR in

PWS’ higher exposure risk areas.

5 OPNAVINST 5090.1D dated 10 January 2014 is the most updated version of OPNAVINST 5090.1D.

6 Stage 1 D/DBPR does not apply to consecutive systems unless specifically required by the state.

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In accordance with OPNAVINST 5090.1D, SUBASENLON Trident Park must monitor those contaminants that could be contributed by the water distribution system down-stream of the interconnection to the primary supplier including DBP. This

SUBASENLON Trident Park water system monitoring plan meets the intent of the EPA

D/DBPR. This monitoring applies to all Navy water systems regardless of state vari-ance or exemptions from regulatory monitoring requirements.

2019 D/DBPR DRINKING WATER MONITORING PLAN UPDATE SECTION 4

SUBASENLON-TRIDENT PARK DISINFECTANT RESIDUAL

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4. DISINFECTANT RESIDUAL SAMPLING AND MONITORING

Under Navy requirements, the D/DBPR (40 Code of Federal Regulations [CFR]

141.624), requires SUBASENLON Trident Park water systems to adhere to the follow-ing disinfectant monitoring requirements:

1. Analytical requirements in 40 CFR 141.131(c): Lists approved methods for chlo-rine and chloramine (not applicable to SUBASENLON) residual monitoring. The rule allows systems to use N, N-diethyl-p-phenylenediamine kits, among other methods, for measuring these residuals. Only a party approved by EPA or the state may measure the residual disinfectant concentration for compliance.

2. Monitoring requirements in 40 CFR 141.132(c)(1): Requires systems to meas-ure the residual disinfectant concentration at the same time and location as total coliforms are sampled as specified in 40 CFR 141.217.

3. Compliance requirements in 40 CFR 141.133(c)(1): Requires systems to deter-mine Maximum Residual Disinfectant Level (MRDL) compliance using a run-ning annual average (RAA), computed quarterly, of monthly averages of resid-ual disinfectant samples collected for compliance. If the RAA exceeds the

MRDL, a regulated system would be in violation of the MRDL and would nor-mally report to the state and notify the public. Systems that switch between chlorine and chloramines must calculate compliance using results of both chlo-rine and chloramine residual monitoring together. The MRDL for chlorine is 4.0 mg/L and the MRDL for chlorine dioxide (used occasionally by GU during sum-mer time) is 0.8 mg/L (40 CFR 141.65). Any violation of the MRDL must be immediately verified and thoroughly investigated, as it might be an equipment malfunctioning incident (disinfectant residual measurement or chlorine dosing equipment failure), an accident, or an adversarial act within GU water distribu-tion system(s).

7 One residual chlorine sample must be taken at the same time a total coliform sample is taken.

2019 D/DBPR DRINKING WATER MONITORING PLAN UPDATE SECTION 4

SUBASENLON-TRIDENT PARK DISINFECTANT RESIDUAL

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SUBASENLON-TRIDENT PARK SECTION 5

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5. SAMPLING AND SAMPLE ANALYSIS PROCEDURES

This section presents laboratory certification requirements and TTHM and HAA5 sam-ple collection procedures.

5.1 TRAINING AND CERTIFICATION REQUIREMENTS

SUBASENLON Trident Park can use a state-certified contract laboratory8 to collect

D/DBPR samples from its distribution system or can choose to collect these samples using its own staff (e.g., SUBASENLON Public Works Department Environmental Divi-sion staff). If SUBASENLON Trident Park chooses to collect its own samples, as a best management practice, it is recommended that only trained individuals9 collect D/DBPR samples. Adequately trained personnel approved by the NAVFAC MIDLANT PM 10 must conduct measurements of residual disinfectant concentrations (40 CFR 141.74).

Prospective samplers should successfully complete the A-4A-0026 Environmental

Quality Sampling course. The Inter-service Environmental Education Review Board, sponsored by Civil Engineer Corps Officers’ School, offers the course. This course sat-isfies Navy training requirements for Navy environmental samplers (OPNAVINST

5090.1D) by providing the following training:

• Basic sampling techniques (avoidance of cross-contamination, use of preserv-atives)

• Specific sampling techniques for all environmental media including potable water

• Completion of environmental sampling paperwork (sample container labeling, field log books, Chain of Custody (COC11) documentation)

8 SUBASENLON Trident Park must make sure to use a state certified laboratory accredited for all required DBP parameters (i.e., TTHM and HAA5). Appendix C provides a list of In-state certified laboratories for drinking water testing.

9 Based on RCSA Section 19-13-B102(e)(7)(A), water samples shall be collected by technical personnel employed by an environmental laboratory approved by the department under section 25-40 of the Con-necticut General Statutes or a certified distribution system operator, a certified treatment plant operator, a sanitarian, an employee of the department, or a person under the direct supervision of either a certified distribution system operator or a certified treatment plant operator.

10 In this plan, the PM replaces the State or the primacy agency.

11 Appendix C includes an example COC form.

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• Health and safety considerations

• Field-testing techniques (use of pH meter, temperature indicator).

Appendix C provides typical sampling documentation maintained at SUBASENLON water system, including an example COC form and list of outside contractors (e.g., state certified laboratory or GU).

5.2 SAMPLE COLLECTION PROCEDURES

The following items must be prepared and checked before each sampling event.

Items for Sampling

• Sample vials provided by laboratory (most laboratories will provide sample vials with proper preservative and dechlorinating agents): Refer to Table 5-1 for the proper sampling containers for each DBP analytical method.

• Small bottle of 1:1 hydrochloric acid and eye dropper or Pasteur pipette, as pH adjustment is necessary for some TTHM methods (many laboratories will provide ampules with acid for pH adjustment). Take care to follow the specific sampling procedure provided by the analytical laboratory.

• Waterproof labels and permanent (indelible ink) marker

• Ice/coolant and cooler

• Bubble wrap and plastic bags for packaging samples for shipment to the la-boratory (usually provided with the sample vials by laboratory)

• COC Form provided by laboratory

• Disposable gloves of latex (natural rubber) and nitrile material for sampling

The following steps describe the general sampling procedures, as recommended in

EPA12 guidance, to follow when collecting TTHM and HAA5 samples.

TTHM and HAA5 Sampling Procedures

• Label each sample vial. Use waterproof labels and indelible ink. Each label should include the following information:

− Unique sample identification

− System name

− Sample location

− Sample date and time

− Analysis required, if not already on label

12 Initial Distribution System Evaluation Guidance Manual for the Final Stage 2 Disinfectants and Disinfec-tion Byproducts Rule (Appendix C of the guidance document). EPA 816-B-06-002 (January 2006).

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• Be sure to understand and follow the specific sampling procedure provided by the analytical laboratory (if provided).

• Remove the aerator from the tap, if there is one present.

• Open the water tap and allow the system to flush until the water temperature has stabilized (usually about 3-5 minutes). The purpose of this step is to en-sure the sample does not represent stagnant water that has set for a long time in the water line between the street and the faucet. The sample should be representative of the water flowing through the distribution system at the chosen sampling point.

• Adjust the flow so that no air bubbles are visually detected in the flowing stream.

• Slowly fill the sample vial almost to the top without overflowing. Use the bottle cap to add a small amount of additional sample water while simultaneously capping the vial to achieve a headspace-free sample OR fill the bottle with sample gently until the meniscus is level with the bottle top and carefully place the cap on the bottle eliminating any air. Be careful not to rinse out any of the preservative/dechlorinating agent during this process. After the bottle is filled, invert three or four times.

• If collecting TTHM samples that require acidification, let the sample set for approximately 1 minute, allowing the dechlorinating chemical to take effect.

Carefully open the vial and adjust the pH of the TTHM sample to < 2 by adding approximately 4 drops of hydrochloric acid for every 40 mL of sample (amount of acid needed will depend on buffering capacity of sample). Recap the vial, and invert three or four times.

• Invert the vial and tap it to check for air bubbles. If bubbles are detected, carefully open the vial and add more sample water using the cap to achieve a headspace-free sample.

• Immediately cool the samples to 4oC by placing them in a cooler with frozen refrigerant packs or ice. Samples should be maintained at this temperature during shipment to the laboratory.

• Complete the COC provided by the laboratory and include it with the sample shipment.

Table 5-1 summarizes test and sampling requirements for DBP parameters.

SUBASENLON – TRIDENT PARK SECTION 5

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Table 5-1 Sampling Requirements of TTHM and HAA5 Analyses

Parameter Method1 Sample Container

Size and Type2 Preservative3,4

Storage Guidelines4

Sample Collection Guidelines

TTHM

EPA 502.2

40 - 120 mL screw cap glass vials with Polytet-rafluoroethylene (PTFE)-faced silicone septum

• Na2S2O3 [sodium thiosulfate] (or ascorbic acid) if TTHMs are the only compounds being determined in the sample.

• Na2S2O3 (or ascorbic acid) and immediate acidification using hydrochloric acid to pH < 2 if the sample is to be dechlorinated prior to the addition of acid.

Keep at 4°C.

14 days maximum hold time.

• Fill bottle to just overflowing, but do not flush out preservatives.

• No air bubbles.

• Do not overfill.

• Seal sample vials with no head space.

• If ascorbic acid is used to dechlorin-ate TTHM samples, then the sam-ples MUST be acidified. Acidifica-tion of TTHM samples containing Na2S2O3 is required if the samples will also be analyzed for VOCs. In both cases, the pH must be ad-justed at the time of sample collec-tion, not later at the laboratory.

EPA 524.2

EPA 524.3

40 - 60 mL screw cap glass vials with PTFE-faced silicone septum

If only TTHM analysis: Na2S2O3 If all VOCs included: use maleic acid or ascorbic acid

EPA 551.1

60 mL screw cap glass vials with PTFE-faced silicone septum

Phosphate buffer & NH4Cl [ammonium chloride] or Na2S2O3 mixture per 60 mL sample

HAA5

EPA 552.1

250 mL (approximately) amber glass bottles fit-ted with Teflon-lined screw caps

NH4Cl

EPA 552.2

50 mL (approximately) amber glass bottles fit-ted with Teflon-lined screw caps

EPA 552.3

EPA 557

40 mL amber glass Tef-lon-lined septum

Standard Method 6251 B

40 mL or 60 mL screw cap glass vials with PTFE-faced silicone septum

Note: Table 5-1 is adapted from Initial Distribution System Evaluation Guidance Manual for the Final Stage 2 Disinfectants and Disinfection Byproducts Rule (Exhibit C.2 - Appendix C of the guidance document). EPA 815-B-06-002 (January 2006).

1) 40 CFR 141.131 (b)

2) Selection of container should be coordinated with the laboratory.

3) Most laboratories will provide sample vials with proper preservative and dechlorinating agents.

4) Refer to EPA Laboratory Quick Reference Guide for Stage 1 and Stage 2 Disinfectants and Disinfection Byproducts Rules and Initial Distribution System Evaluation Guidance Manual for the Final Stage 2 Disinfectants and Disinfection Byproducts Rule (Appendix C of the guidance document) for more detailed information.

2019 D/DBPR DRINKING WATER MONITORING PLAN UPDATE SECTION 6

SUBASENLON-TRIDENT PARK STAGE 2 D/DBPR SAMPLING FREQUENCY

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6. STAGE 2 D/DBPR SAMPLING FREQUENCY AND

SAMPLING SITE SELECTION

This 2019 SUBASENLON Trident Park Stage 2 D/DBPR monitoring plan is the periodic update of the 2014 monitoring plan. It is based on current sampling site availability and population. For SUBASENLON Trident Park, the D/DBPR applies to consecutive

CWSs that do not add a disinfectant to the drinking water within the distribution system.

The maximum contaminant levels (MCLs) for TTHM and HAA5 are the same for the

Stage 1 D/DBPR and the Stage 2 D/DBPR. However, the method of calculating TTHM and HAA5 compliance differs between the two. Stage 2 D/DBPR compliance is based on locational running annual averages (LRAAs) of TTHM and HAA5 concentrations as determined through a monitoring plan developed for the system (40 CFR 141.622).

Compliance is based on meeting the MCL at each monitoring location, instead of using the system-wide RAA required under the Stage 1 D/DBPR.

The state regulations require licensed consecutive systems to comply with the D/DBPR at the same time as the supplier system. Compliance with the Stage 2 D/DBPR by all

PWSs, including GU, began on April 1, 2012 (for GU) and ended on October 1, 2013

(for systems of <10,000 population) (see Appendix B). Although SUBAENLON Trident

Park is not subject to the state regulatory requirements, it can use the same monitoring schedule currently used by GU, or implement a quarterly monitoring schedule of its choosing.

6.1 SAMPLING FREQUENCY

SUBASENLON Trident Park water system serves less than 10,000 people. Table 6-1 summarizes the compliance monitoring requirements under 40 CFR part 141, subpart

H monitoring, for Stage 2 D/DBPR (§141.132) and Table 6-2 presents SUBASENLON

Trident Park Water System D/DBPR monitoring frequency. Table 6-3 lists the D/DBPR regulated contaminants.

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Table 6-1 Monitoring for Stage 2 D/DBPR

Source Water Type

Population Range

Monitoring Frequency

Number of Distribution System Monitoring Locations

Total Loca-tions Per

Monitoring Period

Highest

TTHM

Locations

Highest

HAA5

Locations

TRIDENT PARK

Surface Water 500 to 3,300 Every 90 days (1)

(2) 2 1 1

1) SUBASENLON Systems (CWS) must take at least one dual sample set during the month of the high-est DBP concentrations.

2) Trident Park CWS serves ~700 people (i.e., in the range of 500-3,300) and is therefore required to take individual one TTHM and one HAA5 sample: one at the location during the quarter with the high-est TTHM single measurement, one at the location during the quarter with the highest HAA5 single measurement; one dual sample set per year if the highest TTHM and HAA5 measurements occurred at the same location and during the same quarter.

Table 6-2 SUBASENLON Trident Park Water System DBP Routine Monitor-ing Frequency

SUBASENLON

Water System

Population* Stage 2 DBP Routine Monitoring Sampling

Frequency (Corresponding Regulatory Population Range)

Trident Park ~700

2 (500-3,300) per quarter ** (one individual TTHM and one individual HAA5 sample from the locations with the highest TTHM and HAA5 concentration, respectively).

* Populations are approximate (~) figures

** Only one location with a dual sample set per monitoring period is needed if highest TTHM and HAA5 concentrations occur at the same location.

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Table 6-3 Stage 2 D/DBPR Regulated Maximum Contaminant Level

Regulated Contaminants MCL (mg/L) MCL Goal (mg/L)

TTHM 0.080 LRAA

Chloroform 0.07

Bromodichloromethane 0.0

Dibromochloromethane 0.06

Bromoform 0.0

HAA5 0.060 LRAA

Monochloroacetic acid 0.07

Dichloroacetic acid 0.0

Trichloroacetic acid 0.02

Bromoacetic acid -

Dibromoacetic acid -

6.2 SAMPLING LOCATIONS SELECTION JUSTIFICATION

The Stage 2 D/DBPR included an initial distribution system evaluation (IDSE)13. The

IDSE evaluation study is part of the D/DBPR. The evaluation study requires sampling at various locations within the network to determine critical sampling locations for DBP.

As stated by SDWA regulations, “the goal of the IDSE is to characterize the distribution system and identify monitoring sites where customers may be exposed to high levels of total trihalomethanes (TTHM) and haloacetic acids (HAA5).” The last IDSE studies in the United States (US) were concluded by October 1, 2013.

• Research, including data collected through the IDSE studies in the US, estab-lished that HAA5 levels are highest and TTHM levels are lowest at the point of entry to the distribution system and HAA5 levels are lowest and TTHM levels are highest at the point with the highest water age.

• Many Navy water systems, including SUBASENLON, were not required to de-velop or submit an IDSE report under either 40 CFR 141.601 or 141.602 and meet the already passed deadlines specified in the regulations.

13Stage 1 Disinfectants and Disinfection Byproducts Rule 63 FR 69390, December 16, 1998, Vol. 63, No.

241. Stage 2 Disinfectants and Disinfection Byproducts Rule 71 FR 388, January 4, 2006, Vol. 71, No. 2

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Therefore, with the knowledge gained over more than ten years concerning HAA5 and

TTHM occurrence in the distribution system, selection of appropriate monitoring loca-tions can be based on rationale for identifying locations with high levels of TTHM or

HAA5, rather than an IDSE.

Table 6-4 provides the locations and justification for site selection based on the require-ments of the Stage 2 D/DBPR. Figure 6-1 depicts the monitoring sampling locations on the water supply distribution system map.

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Table 6-4 Trident Park - Stage 2 D/DBPR Compliance Monitoring Locations

Stage 2 Monitoring Site Type

Primary Monitoring Locations

Alternative Monitoring Locations*

Site Selection Rationale Site Name/ Building Number

Sampling Location

Site Name/ Building Number

Sampling Location

High TTHM

54 Michigan Drive, Groton, CT 06340/

Building 54

Kitchen / Restroom

Sink Faucet**

316 Ohio Ave-nue, Groton, CT

06340/Building

Kitchen / Restroom

Sink Faucet**

Buildings (Housing Units) at 54 Michigan Drive and 316 Ohio Avenue water samples, collected from the furthest location in the distribution system and/or measured non-detect disinfect-ant residuals (i.e., <0.02 mg/L) because of their distance from GU connection points (i.e., long resident time). Low disinfect-ant residuals relative to those at other buildings at SUBASENLON Trident Park usually indicate long residence time and correlate with higher TTHM concentrations. There-fore, these locations are good sites for high TTHM monitoring.

High HAA5

14 Florida Street, Groton, CT 06340/ Build-ing 14

Kitchen / Restroom

Sink Faucet**

27 Florida Street, Groton, CT 06340/

Building 27

Kitchen / Restroom

Sink Faucet**

Due to its proximity to the GU water meter pit, the water Build-ing 14 (14 Florida Street) has the shortest residence time. As HAA5 compounds degrade in the water system, EPA suggests locating HAA5 sites in areas with high disinfectant residuals and short water residence time, which corresponds to first cus-tomers on the network. The alternative location of Building 27 Florida Street is also close to the GU interconnection water meter pit.

*If the primary monitoring location is lost through demolition.

** Sampler must field verify the suitability of each sampling site and sampling faucet.

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Figure 6-1 Stage 2 D/DBPR Sampling Location Map

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SUBASENLON-TRIDENT PARK SECTION 7

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7. CALCULATING THE LRAA AND OEL

Compliance with TTHM and HAA5 MCLs for Stage 2 D/DBPR is based on calculating the LRAA at each monitoring location. Based on population served and source water, SUBASENLON Trident Park must monitor for TTHM and HAA5 once per quarter at each of the two selected locations as listed in the above section (see Section 6, Table

6-4). Trident Park must take one individual TTHM sample at the location and during the quarter with the highest TTHM single measurement, and one at the location and during the quarter with the highest HAA5 single measurement. If the highest TTHM and HAA5 measurements occurred at the same location and during the same quarter, one dual sample set per year can replace the two individual samples.

7.1 CALCULATING LOCATIONAL RUNNING ANNUAL AVERAGE

For SUBASENLON Trident Park water system, LRAA calculations are computed as follows and an example is provided as a demonstration for a system that collects TTHM and HAA5 samples quarterly:

• LRAA = (Q1+Q2+Q3+Q4)/4

• The following quarter, LRAA = (Q2+Q3+Q4+Q5)/4

• Q1 through Q5 correspond to TTHM and HAA5 results for samples collected during a calendar quarter at each of the locations in Table 7-1.

• MCL compliance is based on the LRAA of the last four calendar quarters being < MCL for each location as presented in the following example LRAA calculation

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Table 7-1 Example of LRAA Calculation

Date

TTHM

Result mg/L

LRAA for TTHM

TTHM

MCL Vio-lation?

HAA5

Result mg/L

LRAA for HAA5

HAA5

MCL Vio-lation

10/1/2017 0.092 (0.092+0+0+0)/4

= 0.023 mg/L No 0.040

(0.04+0+0+0)/4 = 0.010 mg/L

No

1/2/2017 0.068 (0.092+0.068+0+0)/4

= 0.040 mg/L No 0.020

(0.04+0.02+0+0)/4 = 0.015 mg/L

No

4/1/2018 0.060 (0.092+0.068+0.060+0)/4

= 0.055 mg/L No 0.024

(0.040+0.020+0.024+0)/4 = 0.021 mg/L

No

7/2/2018 0.092 (0.092+0.068+0.060+0.092)/4

= 0.078 mg/L No 0.016

(0.040+0.020+0.024+0.016)/4 = 0.025 mg/L

No

10/1/2018 0.120 (0.068+0.060+0.092+0.120)/4

= 0.085 mg/L Yes 0.052

(0.020+0.024+0.016+0.052)/4 = 0.028 mg/L

No

1/2/2019 0.064 (0.060+0.092+0.120+0.064)/4

= 0.084 mg/L Yes 0.024

(0.024+0.016+0.052+0.024)/4 = 0.029 mg/L

No

4/6/2019 0.052 (0.092+0.120+0.064+0.052)/4

= 0.082 mg/L Yes 0.012

(0.016+0.052+0.024+0.012)/4 = 0.026 mg/L

No

Note: In the US, some states require that regulated systems submit analytical results directly to the State for the State to perform compliance calculations.

However, because SUBASENLON is not a state regulated system, perform the calculations associated with the LRAA in-house and report them to the

NAVFAC MIDLANT PM.

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7.2 CALCULATING OPERATIONAL EVALUATION LEVEL (OEL)

The D/DBPR also requires SUBASENLON Trident Park to calculate operational eval-uation levels (OELs). The purpose of establishing OELs is to reduce peaks in DBP levels and exposure to high DBP levels. The OEL calculations are done for both TTHM and HAA5 at each monitoring location using compliance monitoring results.

The OEL is determined by the sum of the two previous quarter’s TTHM or HAA5 result plus twice the current quarter’s TTHM or HAA5 result at that location, divided by four;

(i.e., OEL = (Q1 + Q2 + 2Q3) / 4).

If an OEL is exceeded, the SUBASENLON Trident Park distribution system must take the following steps to minimize future exceedances:

• Conduct an operational evaluation including examination of the treatment and distribution systems’ operational practices that may contribute to TTHM and HAA5 formation.

• Submit a written report of the evaluation to the PM no later than 90 days after being notified of the analytical results that caused the exceedance(s).

• Keep a copy of the operational evaluation report and make it publicly available upon request.

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SUBASENLON-TRIDENT PARK SECTION 8

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8. PUBLIC NOTIFICATION

OPNAVINST 5090.1D (Chapter 21 Section 3-4) requires Navy water systems to com-ply with the Public Notification requirement (OPNAVINST 5090.1D Chapter 21 Section

3-4(j)) regardless of variance or monitoring requirements. As a state-exempt consecu-tive system that is not required to comply with the Stage 2 D/DBPR (40 CFR 141.624), SUBASENLON Trident Park water system is not required to notify the State or do Pub-lic Notification in case of MCL, MRDL or other Stage 2 DBP-related violations. How-ever, under Navy requirements, compliance with Stage 2 D/DBPR includes monitoring of DBP and disinfectant residual. SUBASENLON Trident Park water system, as a CWS that delivers water that might contain DBP and disinfectant residual in its distribution system, must provide notification as summarized in Table 8-1. Figure 8-1 presents a proposed notification procedure and Appendix D includes notification templates for

DBP RAA and LRAA violations. Table 8-1 presents Public Notification required for

D/DBPR. Highlighted items (in green) are not applicable to SUBASENLON Trident Park and are unlikely to be in the distributed water because they are not used in the treat-ment of the water or are not expected to be at a level of concern to public health if formed through disinfectant degradation (e.g., bromate, chlorite and chloramine).

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Ta…