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-Small Systems- You’re not in Kansas Anymore 2007 CA-NV AWWA. Kevin Ryan USEPA Region 9 415 972-3806 ryan.kevin@epa.gov. Negotiating The Storm of SDWA Regulations. Total Coliform Rule Title 22, IOC’s, SOC’s, OC’s, Rads, Lead and Copper, CCR

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small systems you re not in kansas anymore 2007 ca nv awwa

-Small Systems- You’re not in Kansas Anymore 2007 CA-NV AWWA

Kevin Ryan

USEPA Region 9

415 972-3806

ryan.kevin@epa.gov

negotiating the storm of sdwa regulations
Negotiating The Storm of SDWA Regulations
  • Total Coliform Rule
  • Title 22, IOC’s, SOC’s, OC’s, Rads, Lead and Copper, CCR
  • Surface Water Treatment Rule, IESWTR, UCMR2
  • Long Term 1 & 2 Enhanced SWTR, Filter Backwash Recycling
  • Rule
  • Disinfectants and Disinfection Byproducts Rule: Stage 1 & 2
  • Groundwater Rule – Consecutive System Implications
  • The SDSSTC :Super Duper, Supernumerary,
  • Soon To Come Regulation – you name it, we’ll make it
the yellow brick road the small system path to safe drinking water
The Yellow Brick Road: The small system path to Safe Drinking Water
  • Groundwater Rule
  • TCR
  • D/DBPR Stage 2
  • Beware the Minions

of Evil:

Noncompliance, poor

water quality, etc.

final groundwater rule
Final Groundwater Rule
  • Published in Federal Register November 8, 2006
  • Effective date January 8, 2007
  • Compliance date December 1, 2009
groundwater rule purpose
Groundwater Rule-Purpose
  • To provide for increased protection against microbial pathogens in public water systems that use groundwater sources, using a risk-based approach.
  • Concern is focused on groundwater sources that are susceptible to fecal contamination (septic, sewer, agricultural)
  • Special emphasis on viruses
background gw microbial problems
Background – GW Microbial Problems
  • Waterborne Disease Outbreaks
    • CDC 1991- 2001 (TCR took effect in 1991)
    • GW systems in involved in 51% of all outbreaks
    • GW systems involved in 68 outbreaks; 11,000 illnesses
    • 79% of these involved source water
  • Waterborne Illness Estimate
    • EPA estimate of 185,000 viral illnesses/ year from undisinfected GW systems
  • 26-27% of wells sometimes have fecal contamination (E. coli or Enterovirus)
applicability
Applicability
  • All systems using groundwater
    • No size restriction on Rule & includes consecutive systems receiving finished groundwater (Small Systems)
    • Including systems using both GW & SW
  • Exceptions
    • Groundwater under direct influence of surface water
    • If all GW is combined and treated with SW
groundwater rule mostly a small system rule
Groundwater Rule – Mostly a Small System Rule
  • 99% of all groundwater systems serve <10,000 People
  • 97% of all groundwater systems serve <3,300 People
  • 45% of the US population served by groundwater sources are on small systems
slide9

Community Water Systems

Percent Disinfecting Groundwater

>75%

26%-75%

0%-25%

gwr components briefly
GWR Components, Briefly
  • Sanitary surveys for all GW systems
  • Source monitoring, if coliform bacteria found in distribution system & no treatment
  • Corrective action, if system deficiencies or positive fecal contamination of well
  • If disinfecting, 4-log inactivation/removal of viruses
sanitary surveys
Sanitary Surveys
  • Applies to all size GW systems
  • State does surveys
    • Every 3 years for community systems
    • Every 5 years for non-community systems
  • Significant deficiency identified during sanitary survey requires corrective action
  • Purpose is “to evaluate adequacy of the system’s sources and operations and the distribution of safe drinking water.”
sanitary survey elements
Sanitary Survey Elements
  • State must consider all applicable elements out of these eight:
    • Source
    • Treatment
    • Distribution system
    • Finished water storage
    • Pumps, pump facilities and controls
    • Monitoring, reporting and data verification
    • System management and operations
    • Operator compliance with State requirements
significant deficiencies
Significant Deficiencies
  • Significant deficiencies include
    • Defects in design
    • Defects in operation and maintenance
    • Failure or malfunction of well, treatment, storage or distribution system
  • States set criteria for “significant deficiencies”
    • “to be causing, or have potential for causing, introduction of contamination into the water delivered to consumers”
gw source water monitoring builds on existing tcr
GW Source Water Monitoring Builds on Existing TCR
  • Triggered by TCR coliform-positive sample in distribution system
  • Must sample once at GW source(s) for fecal indicator within 24 hrs
  • If source sample fecal-indicator positive, then additional 5 samples at that source within 24 hrs
    • Unless State requires other immediate action
  • If any repeat source sample is fecal positive, then corrective action required
  • If TCR positive is in consecutive system using GW, system with well has to do the monitoring
bacteriological sample site plan changes modifications
Bacteriological Sample Site Plan Changes/Modifications
  • Small systems—Repeat sample set is 4 samples; 1 from positive distribution location, 1 from within 5 sites upstream and downstream, 1 from operating well (triggered source sample)
  • Larger systems—Need a plan for conducting triggered source monitoring and know how to label the samples
bacteriological sample site plan changes modifications16
Bacteriological Sample Site Plan Changes/Modifications
  • Do you have sampling taps on all active wells?
  • Must sample operating wells WHEN a TCR distribution positive sample is obtained (TRIGGERED SOURCE MONITORING)
gw source monitoring state options
GW Source Monitoring – State Options
  • State may require susceptible systems to conduct assessment source water monitoring
  • State may pre-approve a representative source water sampling plan in the event of a TCR positive in the distribution system
  • State may develop a list of distribution system conditions that will cause total coliform positive samples (& waive the source water monitoring if these conditions have occurred).
fecal indicator methods
Fecal Indicator Methods
  • State picks fecal indicator
    • E. coli, enterococci, or coliphage
  • E. coli
    • Any currently approved method (CA/NV)
  • Enterococci
    • Multiple-tube (9230B)
    • Membrane filter (9230C)
    • Enterolert (EPA 1600)
  • Coliphage (more expensive)
    • Two-step enrichment presence/ absence (EPA 1601)
    • Single agar layer procedure (EPA 1602)
corrective actions treatment techniques
Corrective Actions – “Treatment Techniques”
  • System/ State consultation within 30 days following notification of significant deficiency or fecal indicator positive source water sample
  • Complete corrective action, or be on a State-approved plan and schedule within 120 days
  • Corrective action options
    • Correct significant deficiency
    • Provide alternate water
    • Eliminate source of groundwater contamination
    • Provide 99.99% (4-log) virus reduction
disinfection compliance monitoring
Disinfection – Compliance Monitoring
  • If providing 4-log disinfection treatment for viruses, must demonstrate effectiveness and reliability
  • For chemical disinfection, maintain residual
    • Continuous monitoring for large (> 3,300)
    • Daily grab sample at peak flow for small (<3,300)
  • For membranes, State requirements
  • For alternatives, State requirements
treatment technique violations
“Treatment Technique” Violations
  • Failure to correct sanitary survey deficiencies in a timely manner
    • 120 days or per State schedule
  • Failure to correct source fecal contamination in a timely manner
    • 120 days or per State schedule
  • For systems disinfecting to 4-log, uncorrected failure >4 hours
public notification
Public Notification
  • Tier 1 for fecal indicator positive in source water
    • Within 24 hours
  • Tier 2 for treatment technique violations
    • Within 30 days
  • Tier 3 for monitoring/ reporting violations
    • Within one year
consumer confidence report must include information on
Consumer Confidence Report – Must Include Information on:
  • Source fecal contamination and how it was or is to be corrected under a State-approved plan.
  • Any uncorrected significant deficiencies and the State-approved corrective action plan.
    • State may require a system to report how a resolved significant deficiency was corrected.
california nevada program discretion
California & Nevada Program Discretion
  • Across the country, the approach to implementing the GWR may be significantly different than the approach California or Nevada will use.
  • USEPA with workgroup, built into the GWR considerable State Discretion.
  • Some States already require that each entry point to a distribution system be chlorinated (Different than 4-log virus inactivation)
  • Some States have sensitive aquifers and will be requiring sensitivity assessments as part of their implementation of the GWR
nevada perspective
Nevada Perspective
  • May take a Case-by-Case approach
  • Still thinking
  • Contact Judy Neubert

(775) 687-9523

jneubert@ndep.nv.gov

california perspective
California Perspective
  • GWR builds on existing Regs, Policy
    • Record keeping requirements associated with triggered source monitoring after distribution positives
    • Proper well construction/location will minimize your GWR headaches along with a good distribution system
california perspective27
California Perspective
  • Any well with fecal contaminants should be destroyed and replaced with a new source that is constructed/located properly
  • A single barrier of treatment (even 4 log disinfection) is NOT adequate. California will likely require full surface water treatment if the source isn’t replaced
california perspective28
California Perspective
  • Boil Water Orders will likely be issued when a well must remain in service that produces fecal contaminants
  • Raw water monitoring of chlorinated sources will provide valuable information regarding the groundwater quality if chlorination is practiced
  • Good well construction and location, along with a well maintained distribution system will minimize the impact of the GWR on your system
more gwr information
More GWR Information
  • USEPA’s web site: http://www.epa.gov/safewater/disinfection/gwr/
  • Safe Drinking Water Hotline 1-800-426-4791
  • EPA Posts guidance manuals on the EPA web site such as:
available guidance manuals
Available Guidance Manuals
  • Consecutive System Guide for the Ground Water Rule

EPA 815-R-07-020 July 2007

  • Ground Water Rule Source Water Monitoring

EPA 815-R-07-019 July 2007

continuing on our journey small system path to safe drinking water
Continuing on our Journey: Small System path to Safe Drinking Water

X Groundwater Rule

X Total Coliform Rule

  • D/DBPR Stage 2
tcr gwr stage 2 d dbpr
TCR + GWR = STAGE 2 D/DBPR
  • Focus on Schedule 4 Systems < 10,000
  • Consecutive systems are required to comply with the Stage 2 DBPR.
  • Applies to ALL systems using a disinfectant (usually Chlorine or Chloramines)
  • Stage 2 DBPR – There are 4 IDSE Options

1) Very Small System Waivers (VSS)

2) 40/30 Certification - Handout

3) Standard Monitoring -Handout

4) System Specific Study (not feasible)

stage 2 dbpr
Stage 2 DBPR

IDSE Options

1

3

4

2

VSS

Waiver

40/30 Certification

Standard Monitoring

System Specific Study

Existing Data Only

New and Existing Data

Choose Stage 2 TTHM/HAA5 Sites for Compliance

Conduct Stage 2 Compliance Monitoring

LRAA

very small system waiver
Very Small System Waiver
  • Systems must
    • Serve fewer than 500 people
    • Have taken qualified TTHM and HAA5 samples
      • EPA approved methods
      • Acceptable locations
      • Taken in the months of the warmest water temperature (July, August, or September
      • Granted Automatically (April 1, 2008)
vss waivers
VSS Waivers
  • Waivers effective immediately
    • No application necessary
  • Primacy agency can require Standard Monitoring or System Specific Study
  • VSS Waiver is only a waiver from additional IDSE activities
    • No Standard Monitoring or System Specific Study Plan
    • No IDSE Report
  • Continue compliance with Stage 1 DBPR until Stage 2 DBPR begins
    • Complete a monitoring plan for the Stage 2 DBPR
option 2 40 30 eligibility criteria
Option 2: 40/30 Eligibility Criteria
  • Systems must have taken all required Stage 1 DBPR TTHM and HAA5 samples:
    • For eight consecutive calendar quarters
      • No individual sample can have exceeded:
        • 0.040 mg/L for TTHM
        • 0.030 mg/L for HAA5
      • No TTHM or HAA5 monitoring violations
  • Note: EPA or the state may deny the certification for any reason, even if system meets all eligibility criteria
40 30 certification
40/30 Certification
  • Primacy agency can require Standard Monitoring or System Specific Study
  • Certification is only a waiver from additional IDSE activities
    • No IDSE Monitoring or Report (ref. Schedule)
  • Continue compliance with Stage 1 DBPR until Stage 2 DBPR compliance begins
    • Complete a monitoring plan for Stage 2 DBPR due on or after April 1, 2012
40 30 required language submit by april1 2008
40/30 Required Language: Submit by April1, 2008
  • individual Stage 1 DBPR compliance sample collected from ________ to _______ were less than or equal to 0.040 mg/L for TTHM and 0.030 mg/L for HAA5. I understand that to be eligible, each individual sample must be below these values. I also certify that this PWS did not have any Stage 1 DBPR monitoring violations during this time period.

Signature: _______________ Date: ______

option 3 standard monitoring schedule 4 10 000
Option 3: Standard MonitoringSchedule 4 < 10,000
  • The purpose of Standard Monitoring is to find the best representative sites for Stage 2 DBPR monitoring of TTHM and HAA5
  • Submit Plan: 4/1/2008

Complete Monitoring: 3/31/2010

Submit IDSE Report: 7/1/2010

selecting high tthm sites
Selecting High TTHM Sites
  • Good TTHM sites
    • Downstream of tanks
    • Dead ends, but prior to last customer and prior to last hydrant or blowoff
    • Hydraulic dead ends and mixing zones
    • Downstream of booster chlorination
    • Sites with difficulty maintaining residual
    • Areas with low water use
  • TTHM formation
    • Advanced residence time is primary factor
  • Do Not select
    • Dead ends with no users
    • Sites upstream of booster chlorination
    • Sites after the last hydrant or blowoff
monitoring at high tthm sites
Monitoring at High TTHM Sites
  • The monitoring location is called the High TTHM site
    • Cannot use Stage 1 DBPR site
    • Cannot “double up” or use this site more than once to represent another type of Standard Monitoring site
    • Must sample for BOTH TTHMs and HAA5s at this site.
  • Tip! If you are also required to choose one or more High HAA sites, select your High TTHM sites after you have chosen your High HAA sites.
  • Remember to explain why you chose your High TTHM site at your particular location.
selecting high haa5 sites
HAA5 formation

Residence time, but also consider biodegradation

Do not select

Areas with known biofilm growth

Areas with free chlorine residual less than 0.2 mg/L or with chloramine residuals less than 0.5 mg/L

Good HAA5 sites

Downstream of booster chlorination

Sites with low but detectable residual

Areas of high historic levels

Other

Tanks

Dead ends, but prior to last customer and prior to last hydrant or blowoff

Hydraulic dead ends and mixing zones

Areas with low water use

Selecting High HAA5 Sites
monitoring at high haa5 sites
The monitoring location is called the High HAA5 site

Cannot use Stage 1 DBPR site

Cannot “double up” or use this site more than once to represent another type of Standard Monitoring site

Must sample for BOTH TTHMs and HAA5s at this site.

Remember to explain why you chose your High HAA5 site at your particular location.

Monitoring at High HAA5 Sites