EPA Groundwater Rule

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EPA Groundwater Rule

• 40 CFR Parts 9 141 and 142

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Reasons for the Groundwater Rule

• To protect public health due to viruses and other
  bacterial exposure
• To prioritize attention to high-risk sources
• Identifying deficiencies and requiring them to be
  fixed

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Groundwater Rule who?

• Community (including consecutives)
• Non-transient Non-community
• Transient Non-community

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General Requirements

• Triggered source water monitoring, for
  non-disinfecting/inadequate disinfecting water
  systems
• Compliance monitoring
• Certification with 99.99 removal (Point Of Entry
  To Distribution (POETD) chlorine residual on
  Monthly Operating Reports (MORs) now a federal
  issue)

• Compliance with all aspects of rule begins
  December 1, 2009
• Sanitary Survey
• If disinfection, 4 log inactivation or removal
  for viruses (99.99)
• Treatment technique required for either
  contaminated source water or significant
  deficiencies

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Quick Reference Guide (EPA)
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Sanitary Surveys

• Significant deficiencies Temporary Operating
  Permit (TOP) with special conditions, with
  deadlines for completion.
• Sanitary Survey is a tool to help identify
  potential for bacteriological contamination
• Correcting deficiencies and reporting to the
  Water Supply Division is crucial.

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Sanitary Surveys

• Significant deficiencies found during Sanitary
  Survey
• Must report to Water Supply Division within 30
  days after receiving written Sanitary Survey
• Plan within 120 days of the Sanitary Survey
• Corrective Action Plan (may be a schedule)
• Plan will be put in Operating Permit
• Or correct deficiency already

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Source Sample Taps

• Source Sample Taps
• To be located before any water treatment
  connections
• Are able to sample each source independently
• If unable to take an independent source sample,
  then all sources will be subject to corrective
  action if tested positive for fecal contamination
• In the Water Supply Rule, Appendix A, Part 2.11
  Sample Taps requirement

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Source Sample Tap Location

• Sample Tap Location Submittals
• Submit sketch of source locations and source
  sample tap locations to WSD
• If multiple sources are combined prior to the
  sample tap, include a paragraph describing how
  separate source samples will be taken from each
  source if that is possible
• Include water system name and WSID

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Microbial Source Monitoring

• Triggered microbial source monitoring
• Triggered by Total Coliform Rule
• If 4 log virus treatment not provided, and
• Distribution Coliform sample is positive, then
  source monitoring required
• Sampling Requirements
• ASAP sample from each source
• Fecal positive results will result in Boil Water
  notice, and 5 confirmatory additional source
  samples required ASAP

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Consecutive Systems

• If meeting 4 log virus treatment no source
  sampling required
• Consecutive system must notify wholesaler to do
  source monitoring ASAP if consecutives
  distribution coliform sample is positive
• Wholesaler must perform source monitoring within
  24 hours of positive result
• If fecal positive, wholesaler most notify all
  customers, including all consecutive systems
  ASAP, and do 5 source repeats

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Groundwater Rule Flow Sheet

• NOTES
• If Water Systems have 3 MCL/Boil Water Notice
  events in a 12 month period the system must meet
  4 Log disinfection.
• Non-Acute Boil Water Notice required for systems
  with the following increased monitoring
  positives
• Initial T.C. present
• Source T.C. present
• 1 or more of the 4 Repeat samples T.C. present

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Corrective Action Plan

• Corrective Action Plan new source, eliminate
  contamination, or use disinfection permanently.
• New Source Permitting through Hydrogeologists
• Identify deficiency causing contamination and
  correct problem
• Meet 4 log virus treatment

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4 Log Virus Treatment

• Existing groundwater sources
• Certification of 4 log treatment due 12/1/09
• See Calculation Worksheet (Slide 17)
• Compliance monitoring also begins 12/1/09
• GW systems gt 3300 continuous monitoring of
  residual disinfectant concentration at point of
  entry to distribution
• Record the lowest residual on MOR
• Grab samples every 4 hours if equipment failure,
  and must fix in 2 weeks

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4 Log Virus Treatment

• Existing groundwater sources
• GW systems lt 3300 grab sample during hour of
  peak flow, of residual disinfectant concentration
  at point of entry to distribution
• If residual less than residual needed to meet 4
  log, grab samples every 4 hours until residual
  back to required level
• Continuous monitoring can be done if desired

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Calculation Worksheet (CT)
17
Handout on 4 Log Disinfection
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Monthly Operating Report (NEW)
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Change in Monthly Operator Report

• Monthly Operating Reports have changed to add
  Groundwater Rule requirements
• Section 7. on Page 1
• Continuous monitoring and or equipment failure
• Finished Water Information Page 2 for 4 Log
  disinfection
• pH
• Temp
• CT

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Discontinuing treatment

• If water system chooses to discontinue 4-log
  virus treatment, the state must approve, and the
  system is then subject to triggered source water
  monitoring requirements.
• Contact Water Supply Division (WSD)immediately
• Water System will need to report to the WSD as to
  why 4 Log disinfection is not needed

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Potential Violations

• Water system not in compliance with permit with
  schedule of compliance for significant
  deficiencies
• Water system does not complete corrective action
  plan in response to fecal source water detection
• Water system fails to monitor, or maintain 4 log
  treatment, re GWR
• Water system fails to provide public notice

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Public Notice

• Consumer Confidence Reports must include notice
  of significant deficiencies and fecal
  contamination in source water
• Annual CCR must be used until deficiency
  corrected
• NTNCs will continue to require TOP Public
  Notice for significant deficiencies (PN for
  fecal will be done separately).

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Public Notice Contains

• Nature and extent of deficiency
• Survey date
• State approved plan and schedule (permit) for
  corrective action, including interim measures
• Progress to date

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Reporting Recordkeeping

• Notify WSD within 24 hours if treatment not
  working
• Notify WSD within 30 days of completing
  corrective action (already reqd for signif.
  deficiencies), and keep documentation 10 years
• Keep public notice documentation 3 years
• Consecutives keep copy of notification to
  wholesaler for 5 years

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Reporting Recordkeeping (cont.)

• Keep copies of construction and operating
  permits, and any other document that references
  state-specified minimum disinfection residual,
  for 10 years
• Keep records of lowest daily residual, and
  date/duration of failures gt 4 hours, for 5 years

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Water Systems Potentially Effect

• Positive Results from January 2008 through
  December 2008
• Community - 21
• Non-Transient Non-Community -18
• TNC - 32
• Total Number of Water Systems Effected 24
• NOTE This only accounts for groundwater systems
  that had at least one Total Coliform Postive
  during 2008. Many Water System had more than one
  positive during 2008, which would require them to
  take source sampling more than once during the
  given year. (ie One system had 22 Total
  Coliform postive results during 2008)

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Proactive Approach to the Groundwater Rule

• Dont have significant deficiencies at your
  system. If you do have significant deficiencies,
  fix them before the Temporary Operating Permit is
  issued.
• Protect your source. Experience shows most
  coliform issues due to storage and distribution,
  but dont take it for granted.

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Contact Information

• Water Resources
• Rodney Pingree (Section Chief) 241-3418
• Compliance and Operations
• Jean Nicolai (Section Chief) 241-3405
• Julie Hackbarth (Compliance and Certification
  Mgr.) 241-3410
• Tim Raymond (System Operations Mgr.) 241-3419
• Matt Guerino (TCR Coordinator and Cert. Officer)
  241-3415
• Water Supply Division Website
• www.vermontdrinkingwater.org
• EPA Website
• www.epa.gov/safewater/disinfection/gwr