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The Ground Water Rule and You. Advanced Small Water System Course 2013. GWR – Presentation Outline. Its Purpose Key provisions (required sampling, terminology, compliance actions, etc.) Results of Source Monitoring to Date Tools for Water Systems

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The ground water rule and you

The Ground Water Rule and You

Advanced Small Water System Course

2013


The ground water rule and you

GWR – Presentation Outline

  • Its Purpose

  • Key provisions (required sampling, terminology, compliance actions, etc.)

  • Results of Source Monitoring to Date

  • Tools for Water Systems

  • Class Exercise: Coliform Sampling Plan, Lab Slip Terms


The whole point of the groundwater rule gwr

The whole point of the Groundwater Rule (GWR):

To protect us from fecal contamination (either bacteria or viruses) in the source water.


The whole point of the groundwater rule gwr1

The whole point of the Groundwater Rule (GWR):

If it’s not in the source water... GWR does not apply

If it’s not fecal… GWR does not kick in


Significant deficiencies

Significant Deficiencies

New, with the GWR:

DWP has explicit authority to see that GW systems correct significant deficiencies/rule violations;

Establishes a timeline for correcting these deficiencies identified during a water system survey.


Significant deficiencies1

Significant Deficiencies


Significant deficiencies2

Timeline – Systems Must:

Significant Deficiencies

Consult with their regulator (County or State DWP) within 30 days of written notice, to explain how the system plans to correct the deficiencies ; and

Complete the action (or be on an approved schedule to complete it) within 120 days.


Significant deficiencies timeline

Significant Deficiencies -Timeline

July

September

October

August

Survey conducted

30-day Consultation Deadline

November

Survey/ Notice of deficiency received

120-day Correction Deadline


Significant deficiencies3

Significant Deficiencies

Failure to comply with the correction requirement will result in:

A Violation, and

A Tier 2 (30-day) Public Notice


Are fecal microbes in your source water

Are Fecal Microbes in Your Source Water?

How would you know if you only sample water that has already been disinfected?

Must adjust the sampling approach based on whether or not your system has disinfection treatment


Are fecal microbes in your source water1

Are Fecal Microbes in Your Source Water?

Of the 3,155 groundwater systems in Oregon:

No disinfection treatment (66%)

Either UV or unverified chlorine disinfection treatment (33%)

Treatment with ongoing Compliance Monitoring (1%) – will describe later


So which boat are you in

So which boat are you in?

Oregon GW systems


The ground water rule and you

The GW Rule is intended to protect us from fecal contamination (bacteria and viruses) in the source water. How does that play out in each of these situations?


Boat 1 no disinfection treatment

Boat 1: No Disinfection Treatment

If there’s fecal contamination at the source, E. coli will show up in routine distribution testing


Boat 1 no treatment when does gwr say to sample at the source

Boat 1: No Treatment –When does GWR say to sample at the source?

  • Since the routine samples already show the microbial content of the source water…

    • Only impact of the GWR: After a positive routine, take 1 sample from each active source (& mark it as “source”). We’ll hear more about this “triggered sampling” in a bit…


Boat 3 compliance monitoring 4 log virus inactivation 99 99 daily monitoring of chlorine residual

Boat 3: Compliance Monitoring = 4-log Virus Inactivation (99.99%) + Daily Monitoring of Chlorine Residual

4-log viral inactivation


Boat 3 compliance monitoring when does gwr say to sample at the source

Boat 3: Compliance Monitoring - When does GWR say to sample at the source?

No, not really

Does it make sense to keep taking raw source samples if their treatment is confirmed to inactivate fecal microbes, and they monitor it every day?


Leaving us with boat 2

Leaving us with Boat 2 -

Boat 2 = Systems with disinfection treatment, but not verified for 4‑log inactivation of viruses (33% of OR groundwater systems) Is this you?

How does the GWR apply to this “in between” situation?


Boat 2 treatment that is not verified as 4 log for viruses

Boat 2: Treatment that is not verified as 4-log for viruses-

Viruses (e.g., adenoviruses) are more likely to survive standard UV treatment than bacteria.

Hmm – no fecal bacteria/E. coli there, but… look at those “v”s!

v

v v


If tap water samples show no fecal bacteria e coli

If tap water samples show no fecal bacteria (E. coli) -

Factoid: “Norwalk and Norwalk-like viruses are recognized as the major causes of waterborne illnesses world-wide.” Symptoms: watery diarrhea and vomiting

v

v v

How can we tell if a fecal virus might remain in the drinking water?


Test water for viruses

Test water for viruses?

$$$

Not so easy. It’s hard to take valid virus samples, and they are expensive lab tests


Let s be practical

Let’s be practical -

Can we narrow down the likelihood of fecal viruses in a given source?

Well, “fecal contamination” would include fecal bacteria as well as viruses, so…


Voila we can test for fecal bacteria at the source

Voila! We can test for fecal bacteria at the source!

We can use a standard test for fecal bacteria (E. coli) as an indicator for ANY fecal contamination.

Bonus feature - Everyone is used to taking coliform samples for the lab already, and they are fairly inexpensive.


If the source sample is negative for fecal bacteria e coli

If the source sample is negative for fecal bacteria (E. coli)…

Possible Source Water Test Results:

E. coli negative

E. coli negative

E. coli positive

v b v b v b v

v v v

But still fecal viruses present?

- Not likely

Means fecal contamination

No fecal contamination

Chances are good there is no fecal contamination in the source water, and no fecal viruses to worry about.


So source water coliform tests will tell if there are fecal contamination risks

So, source water coliform tests will tell if there are fecal contamination risks


Back to how the gwr applies to boat 2

Back to how the GWRapplies to Boat 2

  • What sampling is required?

In this situation, the GWR gives both:

  • A regular time interval; plus

  • A circumstance that triggers sampling at the source for the fecal indicator (E. coli).

Boat 2 = systems with treatment but not verified for 4‑log inactivation of viruses


The ground water rule and you

GWR – Presentation Outline

  • Its Purpose

  • Key provisions:

    • Water System Surveys & Significant Deficiencies

    • Finding Fecal Bacteria & Viruses in Source Water

    • Source Water Monitoring – Terminology

    • If Fecal Contamination in Source - Public Notice & Corrective Action


Types of source water monitoring under the gwr

Types of Source Water Monitoring under the GWR

  • Assessment Source Monitoring

  • Triggered SourceMonitoring

  • Additional (or “Confirmation” )Source Monitoring

Wellhead with sample tap


1 assessment source monitoring

1. Assessment Source Monitoring

“Assessment Monitoring” is sampling on a regular schedule, not tied to another test’s result. There are two types under GWR:

  • Annual sampling - Every GW system* that disinfects must submit at least 1 source sample per year

*Unless conducting Compliance Monitoring


1 assessment source monitoring1

1. Assessment Source Monitoring

  • Monthly Monitoring:

  • Only applies if notified by the Dept

  • Is short-term (ends after a year)

  • Is aimed at sources susceptible to fecal contamination

  • Higher risk sources identified based on both hydrogeologic sensitivity and proximity of contaminants


Identifying systems for monthly assessment source monitoring

Identifying Systems for Monthly Assessment Source Monitoring

Data sources:

  • Source Water Assessment Reports;

  • Monitoring history;

  • Staff knowledge of GW source


Monthly assessment source water monitoring

Monthly AssessmentSource Water Monitoring

The Source Water Assessment reports identify:

  • Inadequate source construction

  • Highly sensitive aquifer characteristics, and

  • Fecal contaminant sources within the 2-year Time-of-Travel Zone

time of travel to well


Inadequately constructed well susceptible to fecal contamination

Inadequately Constructed Well Susceptible to Fecal Contamination


Assessment monitoring results

Assessment Monitoring Results


2 triggered source monitoring

2. Triggered Source Monitoring

GW systems* must collect triggered source samples when:

  • A routine coliform distribu-tionsample is positive (that’s the “trigger”).

*Unless conducting Compliance Monitoring


2 triggered source monitoring1

2. Triggered Source Monitoring

Basically, the GWR uses the presence of bacteria in the distribution system as another time to check the microbial content of the source water

?


Triggered sampling results

Triggered Sampling Results

TIME


Special case of triggered monitoring purchasing wholesale systems

Special Case of Triggered Monitoring- Purchasing & Wholesale Systems

  • Purchasing Systems:

    • Must notify wholesale system of a TC+ distribution sample.

  • Wholesale Systems (when notified):

    • Must collect samples from all GW sources serving the system

    • If any source sample is fecal positive, must notify consecutive systems served by that GW source


3 additional confirmation source water monitoring

3. Additional/”Confirmation”Source Water Monitoring

If a source sample is E. coli +, the system must confirm findings by:

  • Taking 5 “confirmation” source samples…

    • within 24-hours of being notified about the E. coli+ sample, and

    • from the same source(s) that had an E. coli+ result


3 additional confirmation source water monitoring1

3. Additional/Confirmation Source Water Monitoring

TIME


3 additional confirmation source water monitoring2

3. Additional/Confirmation Source Water Monitoring

  • If any of the 5 confirmation source samples are fecal positive, system must take corrective action.


Scenario exercise what actions would be required if which example matches your situation

Scenario Exercise – What actions would be required if?Which example matches your situation?

  • There’s no disinfection, and a distribution sample is positive?

    • 4 repeats, same as always (1 is at well)

  • There’s UV or chlorine disinfection, and…

  • A distribution sample is positive?

    • 4 repeats from distribution + source sample(s)

  • An assessment source sample is positive for total coliform?

    • If not fecal, it’s not a GWR concern


The ground water rule and you

GWR – Presentation Outline

  • Its Purpose

  • Key provisions:

    • Water System Surveys & Significant Deficiencies

    • Finding Fecal Bacteria & Viruses in Source Water

    • Source Water Monitoring – Terminology and Who Does What

    • If Fecal Contamination in Source - Public Notice & Corrective Action


The operator collects a source sample

The Operator Collects a Source Sample


The next day

The Next Day….

Your sample has tested positive for E. coli !

Meep!


The operator collects five more source samples

The Operator Collects Five More Source Samples


Friday afternoon

Friday Afternoon….

Your samples have tested positive for E. coli !

Meep! Meep! Meep!

Meep!

Meep!


What to do

What to Do?


Call your regulator or maybe they will call you

Call your Regulator!(Or maybe they will call you)

  • Focus is on protecting Public Health from fecal content in the source water.

  • Together, evaluate existing disinfection treatment (if any), leading to a decision on:

    • Whether a Boil Water Notice is required;

    • What interim operating conditions may be imposed.


Public notice

Public Notice

  • If your system does not chlorinate or have UV, the need for an immediate Tier 1 Boil Notice is clear.

  • If disinfected to 4-log virus inactivation, an immediate non-boil notice may suffice.


Example public notice

Example Public Notice


Interim conditions

Interim Conditions

Increased vigilance until long-term corrections are completed, such as:

  • More frequent coliform sampling in the distribution system (e.g., from once to twice per month)

  • If already chlorinating, increase the minimum residual level, to be measured daily at the entry point. If too low, correct within four hours.


Corrective action

Corrective Action

What are the system’s options?

Eliminate source of contamination;

Correct all significant deficiencies & rule violations;

Provide an alternate source of water; or

Provide treatment that reliably achieves 99.99% (4-log) inactivation and/or removal of viruses

[Options to be discussed with regulators, of course…]


The ground water rule and you

1. Eliminate Source of Contamination

Where is the fecal contamination coming from?

Could there be back-flow?

Were recent repairs at the source not adequately disinfected?

Are there animals (live or dead) at the source?


1 eliminate source of contamination

1. Eliminate Source of Contamination

  • Look in the system’s source water assessmentreport for otherpotential sources ofthe contamination.

  • If it’s out of date,may need a fieldvisit with yourregulator.


1 eliminate source of contamination1

1. Eliminate Source of Contamination

Employ a manure management program

Relocate or reduce density of grazing animals

Properly “abandon” inadequately constructed water wells or underground injection control wells

Convert septic to sewered systems

Relocate or improve septic systems


1 eliminate source of contamination for springs

1. Eliminate Source of Contamination for Springs

  • Physical cleaning

  • Improve seal on spring box

  • Prevent animal access

  • Prevent surface water intrusion


Time for spring cleaning

Overgrown brush around the spring provided cover for deer and other animals

E. coli was detected from the springs in 2010

Time for Spring Cleaning

2002

2010


Could it be from surface water influence gwudi

Could it be from surface water influence? (“GWUDI”)

  • All E. coli source sample results are sent to the DWS geologists for evaluation

  • Is there surface water within 500 feet of your source?

  • If yes, you may be directed to conduct an Microscopic Particulate Analysis (MPA) test.


2 correct significant deficiencies rule violations

2. Correct Significant Deficiencies/ Rule Violations

  • Oh, maybe that’s how the E. coli got in…


2 correct significant deficiencies rule violations1

2. Correct Significant Deficiencies/ Rule Violations

  • Well did not meet construction standards

  • May need to reconstruct/obtain new source


3 provide an alternate source

3. Provide an Alternate Source

  • If there’s more than one, you could stop using the “problem” source.

  • If not, …


3 provide an alternate source1

3. Provide an Alternate Source

  • This system is investigating a new well

  • Well started out asa “Dug Hole”


4 last resort provide 4 log inactivation of viruses

4. Last Resort: Provide 4-Log Inactivation of Viruses

This well met construction standards, so they were allowed to install a 4-

log disinfection system with chlorine and tanks for contact time.


Corrective action same fix it timeframe as for significant deficiencies

Corrective ActionSame “fix it” timeframe as for Significant Deficiencies

July

September

October

August

Source sample EC+

30-day Consultation Deadline

November

Confirmation samples EC+; check interim measures to protect Public Health

120-day Correction Deadline


The ground water rule and you

GWR – Presentation Outline

  • Its Purpose

  • Key provisions (required sampling, terminology, compliance actions, etc.)

  • Results of Source Monitoring to Date

  • Tools for Water Systems

  • Class Exercise: Coliform Sampling Plan, Lab Slip Terms


Results of monthly source monitoring after 3 rd year

Results of Monthly Source Monitoring (after 3rd year)


Where are the fecally contaminated sources

Where are thefecally contaminated sources?


What do e coli contaminated wells have in common

What do E. coli Contaminated Wells have in Common?

1979 – New well construction standards


What do e coli contaminated wells have in common1

What do E. coli Contaminated Wells have in Common?


The oregon experience what do e coli contaminated sources have in common

The Oregon Experience: What do E. coli Contaminated Sources have in Common?


What do e coli contaminated sources have in common

What do E. coli Contaminated Sources have in Common?


Implications from data

Implications from Data

Factors most related to GW fecal contamination:

  • Inadequate casing seal construction

  • Aquifer materials

    Mixed sand & gravel or fractured bedrock

  • Water from unconfined aquifers


Early implications from data

Early Implications from Data

Most common fecal sources:

  • Septic systemcomponents

  • Nearby surface water


The ground water rule and you

GWR – Presentation Outline

  • Its Purpose

  • Key provisions

  • Results of Source Monitoring to Date

  • Tools for Water Systems

  • Class Exercise: Coliform Sampling Plan, Lab Slip Terms

  • Resources on the Web

  • New Coliform Sampling Plan Template

  • How to Mark Them on Lab Slips


Gw rule web page on dwp site

GW Rule web page on DWP site

http://public.health.oregon.gov/HealthyEnvironments/DrinkingWater/Pages/gwr.aspx


Pipeline articles

Pipeline articles


New coliform sampling plan template

New Coliform Sampling Plan Template


New coliform sampling plan template1

New Coliform Sampling Plan Template

The type of system and treatment determines repeat sampling requirements


New coliform sampling plan template2

New Coliform Sampling Plan Template

includes slots for triggered source samples


Example 1 1 well no treatment 1000

X

Example 1: 1 well, no treatment, ≤ 1000

1

month


1 well no treatment 1000

1 well, no treatment, ≤ 1000

125 Main

125 Main

120 Main

129 Main

N/A – source is 4th Repeat

Well

Counts as both Repeat & Source Water sample!


Example 2 2 wells no treatment 1000

Example 2:2 wells, no treatment, ≤ 1000

125 Main

125 Main

121 Main

129 Main

N/A Well 1 is 4th RP

Well 1

Well 2

Counts as both Repeat & Source sample

Mark as Source sample only


Example 3 2 wells residual maintenance chlorination 1000

X

Example 3: 2 wells, residual maintenance chlorination, ≤ 1000

1

month


2 wells residual maintenance 1000

2 wells, residual maintenance, ≤ 1000

125 Main

125 Main

121 Main

129 Main

210 Main

Well 1

Well 2

Treatment means source samples CANNOT count as Repeats


Coliform lab form sections

Coliform Lab Form Sections


What type of sample is it

What type of sample is it?

  • DISTRIBUTION Sample Types:

  • Routine

  • Repeat

  • Temporary Routine

  • Special


What type of sample is it1

What type of sample is it?

  • SOURCESample Types:

  • Triggered

  • Confirmation

  • Assessment

  • Special


New coliform lab form

X

New Coliform Lab Form

MM DD YY

Distribution Sample #

AA

Well #1

1) For those of you who disinfect, how would you record a Triggered sample after a routine positive?


Coliform lab form

X

Coliform Lab Form

MM DD YY

Distribution Sample #

AA

Well #1

2) For those of you who do NOT disinfect, how to mark a Triggered sample that also counts as a Repeat? (≤1000 people)


Questions

Questions?

Michelle Byrd (971) 673-0425

[email protected]

Tom Pattee (541) 726-2587 x24

[email protected]


Class exercises

Class Exercises

Coliform Sampling Plan & Lab Slip Labeling Handouts


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