Instructions for Completing Compliance Monitoring Forms for Ultraviolet (UV) Disinfection Treatment Units
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1 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF SAFE DRINKING WATER Remove and recycle these instructions prior to sending the competed form to DEP BACKGROUND Instructions for Completing Compliance Monitoring Forms for Ultraviolet (UV) Disinfection Treatment Units This document contains instructions for the various Pennsylvania Department of Environmental Protection (DEP) forms which pertain to UV disinfection treatment being utilized in water supply operations. Completion of the appropriate forms will satisfy current monthly reporting requirements for this type of treatment. These forms are applicable to public water systems (PWS) which are operating a DEP-approved UV disinfection installation. In order to comply with current regulations, PWS with UV units are required to conduct compliance monitoring that is outlined below. As applicable, separate forms are to be initiated and completed for each UV reactor in operation during a given month. Operational UV installations are being grouped according to the UV reactor dose control methodology that is being utilized at the particular installation. Two different categories are applicable: either the intensity setpoint method or the calculated dose method. This document contains instructions for a total of seven separate reporting forms. It is important to note that not all forms are applicable to each UV reactor installation. A breakdown of these requirements is provided here. These forms are required to be completed at facilities with operational intensity setpoint UV units: Operating Log Units with Intensity Setpoint Dose Monitoring Approach (#3900-FM-BSDW0489) Monthly Calibration Check for UV Intensity Sensors (#3900-FM-BSDW0483) Summary Monthly UV Report Installation with Intensity Setpoint Dose Monitoring (#3900-FM-BSDW0486) The following forms are applicable to those UV units utilizing a calculated dose method: Operating Log Units with Calculated Dose Monitoring Approach (#3900-FM-BSDW0488) Monthly Calibration Check of UV Transmittance Analyzers (#3900-FM-BSDW0484) Monthly Calibration Check of UV Intensity Sensors (#3900-FM-BSDW0483) Summary Monthly UV Report Installation with Calculated Dose Monitoring (#3900-FM-BSDW0485) One other optional form, an Off-Specification Volume Calculation Worksheet (#3900-FM-BSDW0487), is available for PWS use on an as-needed basis. It would be useful for assisting with documenting a reactor s performance when multiple out-of-specification events would occur during a particular day. Validated operating parameters (also referred to as critical operating parameters), along with the corresponding reactor model-specific parameter limits/ranges, are specified in the special conditions section of the respective DEPissued Operations Permit. This information needs to be compared with the data collected during routine daily operation, to ensure that the UV unit is operating as permitted. If any of these critical operating parameters are outof-range during production, that particular UV unit must be taken off-line, typically automatically, so that appropriate corrective measures can be taken. Failure to do so will result in a violation
2 In regard to monitoring form recordkeeping, PWS shall maintain either the original or a copy of these applicable completed monthly forms in their on-site files, so that they would be able to be retrieved upon request by DEP representatives. INSTRUCTIONS: OPERATING LOG UNITS WITH INTENSITY SETPOINT DOSE MONITORING APPROACH (Form #3900-FM-BSDW0489) This log sheet is to be used to document important operational parameters. A separate log sheet needs to be initiated for each UV reactor in operation during the subject reporting month. A qualified treatment plant employee should complete this log form as part of the daily operational duties. If so requested by the PWS, the applicable DEP regional office has an option of approving the use of a suitable alternate monthly operational log sheet, which typically can be generated by the unit s software package. General Information Section: This information is to be entered across the top portion of the form. Fill in the following: Reporting Month/Year: The applicable reporting month and year MM/YY. PWSID: The seven-digit public water system identification number assigned by DEP. Reactor #: The reactor number for which this operational data is being obtained. Dose to be Delivered: Enter the applicable value, in units of mj/cm 2. Typically, when intensity setpoint reactors are operating within validated parameter ranges, the dose being delivered by the unit is 40 mj/cm 2. Chart for Daily Log Entries: Done By: Initials of an authorized PWS representative, who has responsibility for operating this equipment. Run Time: This represents the amount of time that this reactor was in production (on-line) during this calendar day. Enter this value in an hours:minutes format. Production: Volume of water treated by the reactor during that day of operation. Maximum Flow Rate: Enter the value of the highest flow rate encountered during that day of operation. When this parameter is outside of its respective validated range, this unit must be taken off-line. Minimum Intensity: Enter the value of the lowest intensity encountered during that day of operation. When this parameter is outside of its respective validated range, this unit must be taken off-line. Intensity is used to describe the magnitude of UV light measured by UV sensors in a reactor. Time Operated Off-Specification: Enter the total time that this reactor was in production mode with one or more key operational parameters being out of their respective validated ranges. If no off-specification events occurred with this reactor during this calendar day, enter N/A in this column. Off-Specification Volume: This is a calculated value and represents the total volume of water treated on this day during any off-specification operational period(s) involving this reactor. If no off-specification events occurred with this reactor during this calendar day, then enter N/A in this column. Notes: In this column, record any relevant comments or activities
3 INSTRUCTIONS: MONTHLY CALIBRATION CHECK OF UV INTENSITY SENSORS (Form #3900-FM-BSDW0483) This form is to be used to document the calibration checks that are performed on the UV reactor intensity sensors. Calibration checks are needed for all intensity sensors in operation during the subject reporting month. Further, it is recommended that two reference sensors, each having different recalibration due dates, be utilized for this procedure, so as to avoid a situation where no reference sensors would be on-site during a given month. If so requested by the PWS, the DEP regional office has an option of approving the use of an automated calibration check. Corresponding automated test printouts would be attached to one of these forms. Denote refer to automated test printout(s) on that particular section of the form. General Information Section This section allows for identification of the pertinent treatment plant, UV unit, and reporting period. Reporting Month/Year: The applicable reporting month and year MM/YY. System/Treatment Plant: Name of the treatment plant where the UV unit is installed. PWSID: The seven-digit public water system identification number assigned by DEP. Performed By/Date: Individual who is performing the calibration checks and the corresponding date. Documenting the Calibration Checks Unit #: The applicable reactor number. Duty Sensor ID # and Serial #: undergoing a calibration check. The identification number and serial number of the particular reactor sensor Reference Sensor ID # and Serial #: The identification number and serial number of the reference sensor being used in the calibration check. Reference Sensor Intensity: Enter the corresponding reference sensor intensity value, in units of W/m 2 or mw/cm 2. Duty Sensor Intensity: Enter the corresponding duty sensor intensity value, in units of W/m 2 or mw/cm 2. Sensor Calibration Ratio: Calculate this by dividing the duty sensor intensity reading by the reference sensor intensity reading. ACCEPTANCE CRITERIA: For each individual intensity sensor being tested, the calibration ratio must be Acceptability of Results: This is to be denoted in the table s last column. Refer to the above-listed acceptance criteria, and then place a checkmark in the appropriate box. Documenting Recalibration Information This portion would only be filled out if needed. If not necessary during this reporting month, mark the corresponding check box on page 2 of this form. Unit #: The reactor on which the sensor is installed. Sensor Serial #: The serial number of the particular sensor requiring recalibration. Date Sent: This is the date that the sensor is sent to the manufacturer. Company Performing Recalibration: The name of the company that will be conducting the recalibration
4 Date Returned: The date the sensor is received back from the manufacturer. Recalibration Acceptability/Unacceptability: This is determined following return of the affected sensor. Documentation from the recalibration firm is to be reviewed, so that confirmation of an acceptable recalibration can be made by the PWS representative. In the table s last column, place a checkmark in the appropriate box (either Yes or No). Additionally, the system representative making this entry should initial this column as well. As a final step to close out this particular form, have an authorized PWS representative review it for accuracy and completeness. This individual then will print and sign his/her name prior to form submission. INSTRUCTIONS: SUMMARY MONTHLY UV REPORT INSTALLATION WITH INTENSITY SETPOINT DOSE MONITORING (Form #3900-FM-BSDW0486) This form is required to be submitted every month and is applicable to those installations utilizing reactors with the intensity setpoint dose monitoring scheme. It addresses key regulatory reporting requirements associated with this type of treatment. These requirements include: quantifying the percentage of off-specification water produced, summarizing sensor calibration results, and providing off-specification event descriptions with corresponding corrective measures taken. General Information Section Enter the following information in order to identify the applicable PWS: reporting month/year, system/treatment plant name, and the PWSID #. Section A: Calculated Percentage of Off-Specification Water Produced Off-specification water refers to water processed when a reactor would be operating outside of the applicable validated parameter ranges. This section goes through the information needed to calculate this percentage value. Unit Number: Enter the number of the reactor used in production. Complete a separate line item entry for each reactor in use during this reporting month. Total Run Time: Enter the reactor s total time in production during the month. Total Production ( B ): Enter the total volume of water processed by the reactor during the month. # of Off-Specification Events: The total number of occurrences during this month in which the reactor was producing off-specification water. Total Off-Specification Volume ( A ): Enter the total volume of off-specification water produced by the reactor during the month. (If no off-spec events involved this reactor during the month, then this column entry would be 0.) To calculate the % of off-specification water produced: Divide the total volume of off-specification water produced ( A ) by the total volume of water produced ( B ), and multiply by 100. ACCEPTANCE CRITERIA: < 5% of the total volume produced, on a monthly basis. To close out this section, indicate (either Yes or No) whether the acceptance criteria has been met. Section B: Results of Calibration Checks Use a properly completed Monthly Calibration Check of UV Intensity Sensors form as the reference document for completing this section. Calibration checks are needed for all reactor intensity sensors in operation during the subject reporting month
5 In the sequence listed on the form, provide the following information to complete this section: - Total number of reactors at this treatment plant - Number of intensity sensors per reactor - Total number of sensors (multiply the two values from the prior two-line item entries) - Number of sensors used in production operations this reporting month - Referring to the preceding line entry, the number of sensors which had undergone calibration checks this month - From the value listed in the preceding line entry, the number of sensors with calibration results within the acceptable range ACCEPTANCE CRITERIA: acceptable range. All operational reactor intensity sensors must have calibration results within the To close out this section, indicate (either Yes or No) whether the acceptance criteria has been met. Section C: Operational Parameter Information This section is used to provide a synopsis of individual out-of-limit events involving the UV reactor(s) and which occurred during the subject reporting month. Reactor model-specific validation study results are the basis for the acceptance criteria. Applicable validated parameter ranges will include the parameters of flow rate and intensity. These validated parameter ranges typically are specified within the special conditions section of the DEP-issued operations permit. In some instances, it is possible for the validated parameter ranges also to be displayed graphically, using a plot of flow rate versus intensity. First, indicate the Required Dose: check either the 40 mj/cm 2 or Other box. Proceed to provide the following information for each individual off-specification event. Use a separate line item entry for each individual event. So for example, multiple line item entries would be needed on this form if a particular reactor had more than one off-spec event or if the particular treatment plant has more than one operating reactor. As applicable to the PWS treatment plant, descriptive information is to include: Unit Number - This is the number of the reactor. List whether any occurrences of off-specification operation occurred during the month - Indicate either Yes or No. If Yes is indicated, list the date and corresponding out-of-range parameter(s). For the particular event just mentioned, provide a description of corresponding corrective actions taken to resolve the problem. As a final step to close out this entire form, have an authorized PWS representative review it for accuracy and completeness. This individual then will print and sign his/her name prior to form submission. INSTRUCTIONS: OPERATING LOG UNITS WITH CALCULATED DOSE MONITORING APPROACH (Form #3900-FM-BSDW0488) This log sheet is to be used to document key operational parameters. A separate log sheet needs to be initiated for each UV reactor in operation during the subject reporting month. A qualified treatment plant employee should complete this log form as part of daily operational duties. If so requested by the PWS, the applicable DEP regional office has an option of approving the use of a suitable alternate monthly operational log sheet, which typically can be generated by the unit s software package
6 General Information Section This information is to be entered across the top portion of the form. Fill in the following: Reporting Month/Year: The applicable reporting month and year MM/YY. PWSID: Seven-digit public water system identification number assigned by DEP. Reactor #: The applicable reactor number for which this operational data is being obtained. Chart for Daily Log Entries: This information typically is accessed via the unit s SCADA system by utilizing the operator interface panel. Done By: Initials of an authorized PWS representative who has responsibility for operating this equipment. Run Time: This represents the amount of time that this reactor was in production (on-line) during this calendar day. Enter this value in an hours:minutes format. Production: Volume of water treated by the reactor during that day of operation. Required Dose: This value, typically expressed in mj/cm 2, is the dose needed to achieve the target log inactivation for the target pathogen. The reference source for this numerical value is an EPA-published table. Maximum Flow Rate: Enter the value of the highest flow rate encountered during that day of operation. When this parameter is outside of its respective validated range, this unit must be taken off-line. Minimum % UVT: Enter the value of the lowest percent UV transmittance encountered during that day of operation. When this parameter is outside of its respective validated range, this unit must be taken off-line. Minimum Power Percentage (if applicable): This is applicable when the unit has capability to vary lamp power, such as turning off/on banks of lamps or powering down/up lamps. Enter the value of the lowest power percentage utilized during that day of operation. Again, if applicable, when this parameter is outside of its respective validated range, this unit must be taken off-line. Validation Factor: This value, which accounts for the uncertainty associated with the validation testing procedure, is used in the subsequent calculation of the validated dose. Daily Minimum Validated Dose: This value, also calculated by the unit s PLC, will be compared to the required dose to determine the achieved log inactivation credit. Determination of Whether the Minimum Validated Dose is Greater Than the Required Dose: This criteria must be achieved by the subject operating reactor, otherwise the unit must be taken off-line. Time Operated Off-Specification: Enter the total time that this reactor was in production mode with one or more key operational parameters being out of their respective validated ranges. If no off-specification events occurred with this reactor during this calendar day, enter N/A in this column. Off-Specification Volume: This is a calculated value and represents the total volume of water treated on this day during any off-specification operational period(s) involving this reactor. If no off-specification events occurred with this reactor during this calendar day, then enter N/A in this column. INSTRUCTIONS: MONTHLY CALIBRATION CHECK OF UV TRANSMITTANCE ANALYZERS (Form #3900-FM-BSDW0484) This form is to be used to document calibration checks that are performed on the UV reactor transmittance analyzers, or UVT analyzers. These UVT analyzer calibration checks are to be conducted at weekly intervals each month and are needed for all analyzers in operation during the corresponding reporting period
7 If so requested by the PWS, the DEP regional office has an option of approving the use of an automated calibration check. Corresponding automated test printouts would be attached to one of these forms. Denote refer to automated test printout(s) on that particular section of the form. General Information Section This section allows for identification of the pertinent treatment plant, UV unit, and reporting period. Reporting Month/Year: The applicable reporting month and year MM/YY. System/Treatment Plant: Name of the treatment plant where the UV reactor is installed. PWSID: The seven-digit public water system identification number assigned by DEP. Performed By/Date: The individual who is performing the calibration checks and the corresponding date. Documenting the Calibration Checks Note: Before proceeding with this section, confirm that the bench UVT analyzer is within calibration. Unit #: Number of the reactor which has been used in production and on which the analyzer is installed. Analyzer #: The identification number and corresponding serial number of the reactor UVT analyzer undergoing a calibration check. Date: The date of this calibration check. Done By: Name of the individual performing this calibration task. On-line %UVT Reading: Enter the %UVT value measured by the corresponding reactor UVT analyzer. Bench/Grab %UVT Sample Result: Using a calibrated bench meter, measure and enter a corresponding %UVT value. Difference Calculation: This is a subtraction calculation. It is the absolute value of the difference between the on-line %UVT reading and the bench meter %UVT reading. ACCEPTANCE CRITERIA: For each individual UVT analyzer, the difference calculation must be 2.0%. Acceptability of Results: This is to be denoted in the table s last column. Refer to the above-listed acceptance criteria, and then place a checkmark in the appropriate box. Documenting Recalibration Information This portion would only be filled out if needed. If not necessary during this reporting month, mark the corresponding check box on this form. Analyzer #: The appropriate identification number and serial number of the sensor requiring recalibration. Reactor #: The number of the reactor on which the analyzer is installed. Done By: Name of the PWS representative involved with this particular recalibration. Date Performed or Date Sent: Enter either the date performed (for in-house recalibration) or the date sent (if analyzer is being sent off-site). Company Performing Recalibration: If off-site recalibration is to occur, enter the name of the manufacturer or other company that will be conducting the recalibration
8 Date Returned: If off-site recalibration took place, enter the date the analyzer is received back from the outside firm. Recalibration Acceptability/Unacceptability: This determination will occur after the on-site/off-site recalibration is complete. Appropriate documentation from the recalibration is to be reviewed, so that confirmation of an acceptable recalibration can be made by the PWS representative. In the table s last column, place a checkmark in the appropriate box (either Yes or No). Additionally, the system representative making this entry should initial this column as well. As a final step to close out this particular form, have an authorized PWS representative review it for accuracy and completeness. This individual then will print and sign his/her name prior to form submission. INSTRUCTIONS: SUMMARY MONTHLY UV REPORT INSTALLATION WITH CALCULATED DOSE MONITORING (Form #3900-FM-BSDW0485) This form is required to be submitted every month and is applicable to those installations utilizing reactors with the calculated dose monitoring scheme. It addresses key regulatory reporting requirements associated with this type of treatment. Requirements include: quantifying the percentage of off-specification water produced, summarizing sensor and analyzer calibration results, and providing off-specification event descriptions with corresponding corrective measures taken. General Information Section Enter the following information in order to identify the applicable PWS: reporting month/year, system/treatment plant name, and the PWSID #. Section A: Calculated Percentage of Off-Specification Water Produced Off-specification water refers to water processed when a reactor would be operating outside of the applicable validated parameter ranges. This section goes through the information needed to calculate this percentage value. Unit Number: Enter the number of the reactor used in production. Complete a separate line item entry for each reactor in use during this reporting month. Total Run Time: Enter the reactor s total time in production during the month. Total Production ( B ): Enter the total volume of water processed by the reactor during the month. # of Off-Specification Events: The total number of occurrences during this month in which the reactor was producing off-specification water. Total Off-Specification Volume ( A ): Enter the total volume of off-specification water produced by the reactor during the month. (If no off-spec events involved this reactor during the month, then this column entry would be 0.) To calculate the % of off-specification water produced: Divide the total volume of off-specification water produced ( A ) by the total volume of water produced ( B ), and multiply by 100. ACCEPTANCE CRITERIA: < 5% of the total volume produced, on a monthly basis. To close out this section, indicate (either Yes or No) whether the acceptance criteria has been met. Section B: Results of Intensity Sensor Calibration Checks Use a properly completed Monthly Calibration Check of UV Intensity Sensors form as the reference document for completing this section. Calibration checks are needed for all reactor intensity sensors in operation during the subject reporting month
9 In the sequence listed on the form, provide the following information to complete this section: - Total number of reactors at this treatment plant - Number of intensity sensors per reactor - Total number of sensors (multiply the two values from the prior two line item entries) - Number of sensors used in production operations this reporting month - Referring to the preceding line entry, the number of sensors which had undergone calibration checks this month - From the value listed in the preceding line entry, the number of sensors with calibration results within the acceptable range ACCEPTANCE CRITERIA: acceptable range. All operational reactor intensity sensors must have calibration results within the To close out this section, indicate (either Yes or No) whether the acceptance criteria has been met. Section C: Results of UVT Analyzer Calibration Checks Use a properly completed Monthly Calibration Check of UVT Analyzers form as the reference document for completing this section. Calibration checks are needed for all UVT analyzers in operation during the subject reporting month. In the sequence listed, enter the following information to complete this section: - Number of analyzers in operation this month - Referring to the preceding line entry, the number of analyzers which had undergone calibration checks this month - From the value listed in the preceding line entry, the number of analyzers with calibration results within the acceptable range ACCEPTANCE CRITERIA: All operational UVT analyzers must have calibration results within the acceptable range. To close out this section, indicate (either Yes or No) whether the acceptance criteria has been met. Section D: Operational Parameter Information This section is used to provide a synopsis of individual off-specification events involving the UV reactor(s) and which occurred during the subject reporting month. Reactor model-specific validation study results are the basis for the acceptance criteria. Applicable validated parameter ranges will include the parameters of: flow rate, % UV transmittance, minimum validated dose, and power percentage (if applicable to the reactor model). These validated parameter ranges typically are specified within the special conditions section of the DEP-issued operations permit. Additionally, the validated parameter ranges also may be displayed via graphs. First, indicate the Required Dose in units of mj/cm 2. Proceed to provide the following information for each individual off-specification event. Use a separate line item entry for each individual event. So for example, multiple line item entries would be needed on this form if a particular reactor had more than one off-specification event or if the particular treatment plant has more than one operating reactor. As applicable to the PWS treatment plant, descriptive information is to include: Unit Number - This is the number of the reactor. List whether any occurrences of off-specification operation occurred during the month - Indicate either Yes or No
10 If Yes is indicated, list the date and corresponding out-of-range parameter(s). For the particular event just mentioned, provide a description of corresponding corrective actions taken to resolve the problem. As a final step to close out this entire form, have an authorized PWS representative review it for accuracy and completeness. This individual then will print and sign his/her name prior to form submission. INSTRUCTIONS: (OPTIONAL FORM) OFF-SPECIFICATION VOLUME CALCULATION WORKSHEET (Form #3900-FM-BSDW0487) This optional form is available for use by PWS on an as-needed basis. This tool can be used in conjunction with describing individual off-specification events, which occur when a unit operates outside the validated range of any of the key operating parameters. It would be of particular assistance in a situation where multiple out-of-specification events occur in a particular day. In the top portion of the form, enter the following: reporting month and year, the system and treatment plant name, PWSID number, and the reactor number. As appropriate in the subsequent table, enter the following: - The date of this event. - A description of the off-specification event. Include which key operating parameter(s) is out-of-range, the timeframe (start and end times) of the event, and corrective measures taken to resolve the problem. - Representative event flow rate value ( A ) - Time value, which represents duration of the individual event ( B ) - Calculate the off-specification volume treated during the event: [A] * [B] - In the Total box, as appropriate: Add the volume determined for each individual off-specification event, and enter this value as a total for that calendar day. SUBMISSION OF COMPLETED FORMS All applicable completed forms are to be submitted to the appropriate DEP regional office within 10 days following the month in which monitoring occurred. Northwest Region 230 Chestnut St. Meadville, PA Main Telephone: Hour Emergency: Counties: Butler, Clarion, Crawford, Elk, Erie, Forest, Jefferson, Lawrence, McKean, Mercer, Venango and Warren Southwest Region 400 Waterfront Drive Pittsburgh, PA Main Telephone: Hour Emergency: Counties: Allegheny, Armstrong, Beaver, Cambria, Fayette, Greene, Indiana, Somerset, Washington and Westmoreland Northcentral Region 208 W. Third St., Suite 101 Williamsport, PA Main Telephone: Hour Emergency: Counties: Bradford, Cameron, Centre, Clearfield, Clinton, Columbia, Lycoming, Montour, Northumberland, Potter, Snyder, Sullivan, Tioga and Union Southcentral Region 909 Elmerton Ave. Harrisburg, PA Main Telephone: Hour Emergency: Counties: Adams, Bedford, Berks, Blair, Cumberland, Dauphin, Franklin, Fulton, Huntingdon, Juniata, Lancaster, Lebanon, Mifflin, Perry and York Northeast Region 2 Public Square Wilkes-Barre, PA Main Telephone: Hour Emergency: Counties: Carbon, Lackawanna, Lehigh, Luzerne, Monroe, Northampton, Pike, Schuylkill, Susquehanna, Wayne and Wyoming Southeast Region 2 E. Main St. Norristown, PA Main Telephone: Hour Emergency: Counties: Bucks, Chester, Delaware, Montgomery and Philadelphia
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