Transcript Slide 1
The Ground Water Rule (GWR) General Rule Requirements 40 CFR 141.400 thru 141.405 Arizona Department of Environmental Quality August 2009 1 General Rule Requirements – – – – – – – – – – – Purpose of Rule/Relationship to TCR Applicability Basic Requirements Triggered Source Water Monitoring/Representative Monitoring Plan Additional Source Water Monitoring Assessment Monitoring Sanitary Survey Requirements Corrective Action Requirements Compliance Monitoring Compliance Dates Associated with the GWR Violations Associated with the GWR 2 Primary Purpose Require Source Water Monitoring Viruses Protect Public Health Bacteria Require Corrective Action If Necessary Identify GWSs At-Risk To Fecal Contamination Identify Significant Deficiencies 3 Relationship with the TCR The GWR triggered sampling is sparked by a positive ROUTINE TCR sample or INCREASED ROUTINE TCR sample and NOT any positive repeat TCR sample. It is only triggered by monitoring conducted under 141.21 (a), not (b). For more information on the TCR see Total Coliform Rule: A Quick Reference Guide Available on EPA’s Web site at: www.epa.gov/safewater/disinfection/tcr/pdfs /qrg_tcr_v10.pdf 4 To Whom Does the GWR Apply? 1 All PWS Systems relying 100% on ground water 2 Consecutive PWS receiving 100% finished ground water 3 Mixed surface and ground water systems* * Unless combined with surface water (SW) or groundwater under the direct influence of surface water (GUDI) prior to treatment (then the Surface Water Treatment Rule applies) 5 What are the Basic Requirements? 2 1 Sanitary Surveys (w/8 elements) of all GWSs 3* Correction of Significant Deficiencies Source Water Monitoring 4* 5 Treatment/ Elimination of Fecal Contamination Compliance Monitoring *Provisions 3 and 4 = corrective actions 6 The path you take is based upon if you have 4-log removal or not. 4-log Treatment TCR + Result Triggered Source Water Monitoring Additional Monitoring Corrective Actions Compliance Monitoring Sanitary Survey Assessment Monitoring 7 Path #1 If you do NOT have 4-log removal… 8 Source Water Monitoring Scenarios Two possibilities: TRIGGERED (then maybe Additional) SOURCE WATER MONITORING ASSESSMENT SOURCE WATER MONITORING 9 What is Triggered Source Water Monitoring? GWSs must conduct triggered source water monitoring if they: Are NOT conducting GWR compliance monitoring for their 4-log treatment Are notified of a TC+ TCR sample 10 Sampling Requirements PWS must: – Collect a minimum of 1 sample per ground water source within 24 hours of learning of the total coliform positive result – Analyze sample(s) for fecal indicator (E. Coli, enterococci, or coliphage) – Provide public notification of fecal indicator-positive source water sample Extension of 24-hour time limit – State determines exceptions/new time 11 Triggered Source Water Monitoring Consecutives and Wholesale Systems: When a consecutive system is notified of a TC+ sample in the distribution system (DS), they must notify the wholesale system within 24 hours. The wholesale system then has 24 hours to collect a source water sample. If the wholesale system is positive, they must notify all consecutives within 24 hours. 12 Triggered Source Water Monitoring Representative Sampling Plan (this is optional) For multi-source systems – Identify ground water sources that are representative of each monitoring site in the system’s TCR site sampling plan. – In AZ, the PWS must submit the plan to the state by August 31, 2009 for approval prior to December 1, 2009. ADEQ also wants the GWSs to provide: – Map of the water system, including: Location of ground water sources Location of pressure zones Location of storage facilities – Written explanation of how they know which well feeds which section of the distribution system 13 Systems Serving < 1,000 People GWS may use a TCR repeat sample to satisfy the GWR triggered source water sample requirements if: – State allows TCR repeat samples to be taken at the source AND – State approves use of E. coli as fecal indicator under the GWR and lab uses one of the GWR E. coli methods AND 14 – GWS serves < 1,000 people Additional Source Water Sampling Positive Fecal Indicator in Source Water: – If the TRIGGERED sample is Fecal Indicator Positive, then the PWS must collect 5 additional source water samples from the same source for the state-specified FI within 24 hours unless immediate CA is required by state/regulatory agency. – If any of the five additional samples tests positive, the PWS must notify the state/regulatory agency, the public and comply with the treatment technique requirements which requires the state to take one of four corrective actions. – A PWS must respond to any fecal indicator + sample using an approved corrective action. – A Tier 1 Public Notice (PN) is required when any triggered source water sample is fecal indicator+. 15 Assessment Source Water Monitoring States/regulatory agencies may require GWSs that are most susceptible to fecal contamination to conduct assessment monitoring. Usually once or twice a month for twelve months. Assessment source water monitoring samples cannot be used to satisfy TCR routine or repeat sampling. But assessment monitoring can be used to meet triggered source water monitoring requirements. Tools to identify high risk GWSs: – Hydrogeologic sensitivity assessments – Source water assessments – Wellhead protection plans 16 – Historical monitoring data What are the Sanitary Survey Requirements? Must include 8 elements 1) 2) 3) 4) 5) 6) 7) 8) (where applicable): Source Treatment Distribution system Finished water storage Pumps, pump facilities, and controls Monitoring, reporting, and data verification System management and operation Operator certification 17 Significant Deficiencies Are deficiencies that may cause, or have the potential to cause, the introduction of contamination into the finished water Include deficiencies in: – – – – Design Operation Maintenance Failures or malfunctions of source, treatment, storage, or distribution system 18 Source Well in flood zone Improperly constructed well (e.g., improper well surface or subsurface seal) Spring boxes that are poorly constructed and/or subject to flooding Well is located near a source of fecal contamination (e.g., failing septic system or a leaking sewer) 19 Treatment Inadequate application of treatment chemicals (e.g., disinfection contact time is inadequate) Lack of redundant mechanical components where disinfection is required Unprotected cross-connections with treatment chemical system Inadequate treatment process monitoring 20 Distribution System Situation in which negative pressure can result in contamination entering distribution pipes Inadequate disinfectant residual monitorin, when required Unprotected cross-connections 21 Finished Water Storage Inadequate internal cleaning and maintenance of storage tank Lack of proper screening of overflow pipes, drains, or vents Storage tank roofs or covers need repair (e.g., holes or hatch or improper construction) Excessive water age in finished water storage tanks 22 Pumps, Pump Facilities, and Controls Inadequate pump capacity Inadequate maintenance Inadequate/inoperable control 23 Monitoring, Reporting, and Data Verification Failure to properly monitor water quality Failure to meet reporting requirements Inadequate recordkeeping 24 System Management Operation Lack of approved emergency response plan Failure to meet water supply demands/interruptions of service (e.g., unreliable water auxiliary power) Inadequate follow-up to deficiencies noted in previous assessment/survey 25 Operator Compliance with State Requirements Lack of operator training Operator is not certified as required by primacy agency 26 New Sources New sources coming online after November 30, 2009 are required to: OR Complete source water monitoring as required by GWR Provide 4-log treatment of viruses and conduct compliance monitoring within 30 days of source being put in service 27 What are the Corrective Action Requirements? Corrective Action Options: 1) 2) 3) 4) Correct all significant deficiencies. Provide an alternate source of water. Eliminate the source of contamination. Provide treatment that reliably achieves at least 4-log treatment of viruses (using inactivation, removal, or a state-approved combination of 4-log inactivation and removal) before or at the first customer for the GW source. 28 Corrective Action Timeline Event Within 30 Days* *Based on date of event. Notice of significant deficiency OR Notice from the lab of fecal indicator-positive sample from triggered or assessment source water monitoring OR Notice from the lab of fecal indicator-positive sample from at least 1 of 5 additional source water monitoring samples Within 120 Days* State/regulatory agency specifies corrective action OR System consults state/regulatory agency to determine corrective action System must complete corrective action plan OR System must be in compliance with state/regulatory agencyapproved corrective action plan and schedule Systems must take one or more of the 4 corrective actions 29 Treatment Technique Requirements A state may require corrective action in response to an initial fecal indicator positive sample from a triggered source water monitoring sample, triggered monitoring at a wholesale system, or assessment monitoring. A water system using a mixture of SW and GW may not be required to take corrective action if the state/regulatory agency determines that a significant deficiency is in a part of the distribution system served solely by SW. 30 Treatment Technique Requirements The PWS must consult with the state/regulatory agency for appropriate corrective action to be taken within 30 days if the regulator does not designate a specific corrective action. – The PWS must complete the corrective action or be in compliance with a state/regulatory agency approved corrective action plan and schedule, within 120 days of the initial notification. – The state/regulatory agency may require action sooner than the 120 days, or require interim measures to protect public health while the water system is completing the corrective action. 31 Path #2 If you have 4-log removal… 32 Understanding “log” For training, log refers to percent of viruses that are removed or inactivated by treatment: Log 0.5-log 1-log 2-log 3-log 4-log 5-log % removal/inactivation 68.4% 90% 99% 99.9% 99.99% 99.999% 33 What is Compliance Monitoring? A GW source is not required to meet the source water monitoring requirements of the GWR if it has at least 4log treatment (99.99 percent treatment) for viruses. For existing sources that have the required treatment, systems must notify and receive approval from the state by December 1, 2009 Systems must notify the state as new systems are brought on line that have this level of treatment. Systems must conduct compliance monitoring that varies with the type of treatment process used to meet 4-log treatment of viruses, to monitor the effectiveness and reliability or treatment. 34 Understanding “log” “log” refers to the percentage of viruses that treatment remove or inactivate. 0.5-log is equivalent to 68.4% removal/inactivation; 1-log is equivalent to 90%; 2-log is equivalent to 99%; 3-log is equivalent to 99.9%; 4-log is equivalent to 99.99%; 5-log is equivalent to 99.999%. Treatment technologies capable of providing at least a 4-log treatment of viruses include the following: – Inactivation, with a sufficient disinfection concentration and contact time, through disinfection with chlorine, chlorine dioxide, or ozone. Disinfectant concentration and contact time (CT) can be based on existing CT tables or state-approved alternatives. – Removal with membrane technologies with an absolute molecular weight cutoff (MWCO), or an alternate parameter that describes the exclusion characteristics of the membrane, that can reliably achieve at least a 4-log removal of viruses. – Inactivation, removal or combination of inactivation and removal through alternative treatment technologies (e.g., ultraviolet radiation (UV)) approved by the state, if the alternative treatment technology, alone or in combination (e.g., UV with filtration, chlorination with filtration), can reliably provide at least 4-log treatment of viruses. 35 Compliance Monitoring Options 36 Alternative Treatment Technologies Systems may use alternative treatment technologies, alone or in combination, that: – Reliably provide 4-log treatment of viruses AND – Are approved by the state/regulatory agency Systems that use alternative treatment technologies must: – Monitor according to state/regualtory agency-specified monitoring requirements 37 Systems Serving <3,300 People Using Chemical Disinfection Systems must: – Take daily grab samples OR – Meet all the continuous monitoring requirements described for systems serving more than 3,300 people AT – A location approved by the state/regulatory agency If the disinfectant residual falls below the minimum concentration, the system must: – Take samples every 4 hours until the residual meets the required level 38 Systems Serving >3,300 People Using Chemical Disinfection Systems must: – Monitor the residual disinfectant concentration continuously At a location approved by the state/regulatory agency (e.g., entry point) – Record the lowest daily value for residual disinfectant concentration – Maintain a state/regulatory agency-determined minimum disinfectant residual If continuous monitoring equipment fails, a system must: – Collect grab sample every 4 hours – Repair equipment within 14 days 39 Systems Using Membrane Filtration Systems using membrane filtration for 4-log treatment of viruses must meet statespecified requirements for: – Monitoring the membrane filtration process – Operating the membrane filtration 40 Discontinuing 4-log Treatment of Viruses A GWS may discontinue providing 4-log treatment of viruses if: – The state determines it is no longer necessary AND – The system conducts triggered source water monitoring States must document and maintain records of the determination 41 Treatment Technique Violations Violation occurs after 120 days if: GWS with significant deficiency does not correct deficiency or is not in compliance with corrective action plan OR GWS with fecal indicatorpositive source water sample (not invalidated by regulator) does not complete corrective action or is not in compliance with corrective action plan 42 Treatment Technique Violations GWSs conducting compliance monitoring (including state/regulatory agency specified monitoring) that: AND Fail to maintain at least 4-log treatment of viruses at or before the first customer Fail to correct within 4 hours Must issue a Tier 2 notice to the public 43 Monitoring Violations Can result from failure to adhere to: Additional source Triggered source water monitoring requirements water monitoring requirements OR Assessment source water monitoring requirements Compliance monitoring requirements for GWSs using 4-log treatment 44 What Are the Compliance Dates? PWS Requirements Required Beginning: Triggered source water monitoring Corrective actions Compliance monitoring New sources placed in service must meet triggered source water monitoring requirements or provide 4-log treatment of viruses December 1, 2009 States can require GWSs to conduct assessment source water monitoring Required By: Notification of 4-log treatment of viruses State Requirements December 1, 2009 Required By: Complete sanitary surveys for most CWSs December 31, 2012 (and every 3 years after) Complete sanitary surveys for NCWSs and remaining CWSs December 31, 2014 45 (and every 5 years after) Reporting and recordkeeping for systems: GW systems conducting compliance monitoring must notify the state by the end of the next business day any time the system fails to meet state-specified requirements for disinfectant residuals, membrane operating, etc. Water systems completing corrective action must notify the state within 30 days. Water systems must maintain records of: • • • • Corrective Actions (not less than 10 years) Public Notice (not less than 3 years) Sample Invalidation (not less than 5 years) Records related to performance of compliance monitoring (not less than 10 years) • Consecutives (not less than 5 years) 46 • Lowest daily disinfectant level (not less than 5 years) • State Reporting Requirements (not less than 5 years) Special Notice (SN) Special Notice is separate from and in addition to PN and the CCR. Circumstances that require SN differ for CWS and NCWSs. - CWSs may make SN in their CCR - FI+ not invalidated by the state - Annually until SD is corrected - NCWSs must prepare and distribute SN in a manner approved by the state. 47 Mandatory Health Effects Language “Fecal indicators are microbes whose presence indicates that the water may be contaminated with human or animal wastes. Microbes in these wastes can cause short-term health effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a special health risk for infants, young children, some of the elderly, and people with severely compromised immune systems.” 48 Public Notification Summary – Tier 1 Situation or Violation Source water monitoring sample fecal indicator-positive for E. coli, enterococci, or coliphage and not invalidated by the state Report Notify to Public1 State Within 24 Hours Within 24 Hours PN Method TV, hand-delivery, public postings, or other state-approved method (consult your state) 1. Systems are required to send a copy of the PN to the state within 10 days of making the notification. 49 Public Notification Summary – Tier 2 Situation or Violation Report to State Notify Public1 PN Method Within 30 Days Hand-delivery, direct mail, public postings, newspaper or radio announcements Failure to complete required corrective action Failure to comply with a stateapproved correction schedule and plan 2 For systems conducting compliance monitoring, failure to maintain 4-log treatment of viruses and restore 4-log treatment within 4 hours 2 Within 48 Hours 50 50 Public Notification Summary – Tier 2 1. Systems are required to send a copy of the PN to the state within 10 days of making the notification. 2. Community GWSs with an uncorrected significant deficiency must report it in the appropriate CCR. Those systems are also required to report any fecal indicatorpositive samples in the appropriate CCR. They are required to inform the public annually until the state determines that the particular significant deficiency or fecal contamination in the ground water source has been addressed. 51 Public Notification Summary – Tier 3 Situation or Violation Failure to conduct required source water monitoring (triggered, additional, or assessment) Failure to conduct required compliance monitoring Report to State Notify Public1 Consult your state CCR 2 Within (consult your 12 state for other Months specific PN requirements) PN Method 1. Systems are required to send a copy of the PN to the state within 10 days of making the notification. 2. The CCR requirement applies to CWS. NCWSs must use an alternate form of Tier 3 notice approved by their state. 52 Key Points to Take Away Begin compliance on 12/1/09 Applies to all system’s sources not following SWTR If not using 4-log, and you get a TCR+, the GWR is “triggered” Sampling is in addition to TCR requirements Sanitary Surveys will “be tougher” If your PWS has multi sources, consider a Representative Source Water Monitoring Plan Corrective actions required by GWR Notify inspector if adding/discontinuing 4-log treatment Call ADEQ/MCESD if you get a positive total coliform. 53 Guidance Documents Available: Go to the ADEQ website, Ground Water Rule page: http://www.azdeq.gov/environ/water/dw/gw_rule.html The ADEQ webpage will be updated with ADEQ contact information, applications and reporting forms (as they are developed), and links to EPA’s website for guidance documents and quick reference guides. For more information: Donna Calderon, Manager Drinking Water Monitoring and Protection Unit 602-771-4641 or [email protected] 54